Nelson v. Dupree

District Court, M.D. Louisiana·Decided September 11, 2025·No. 3:24-cv-00709·Unknown

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA WILLIAM NELSON, ET AL. CIVIL ACTION VERSUS NO. 24-709-JWD-SDJ ROBERT DUPREE, ET AL.

ORDER In light of Plaintiff’s Motion for Change of Venue (R. Doc. 109), which also suggests that recusal of some or all Middle District judges may be necessary, and in light of Plaintiff’s previous filings suggesting the same (e.g., R. Docs. 34, 105), the Court now finds it appropriate to address the issue of recusal. I. Legal Standard

A motion to recuse is committed to the broad discretion of the targeted judge to determine whether disqualification is appropriate.1 A judge is presumed to be qualified to preside over a case,2 so a movant seeking disqualification bears the burden of proving that a judge is not qualified by clear and convincing evidence.3 Two statutes govern recusal motions: 28 U.S.C. § 144 and 28 U.S.C. § 455.4 Section 144 states as follows: Whenever a party to any proceeding in a district court makes and files a timely and sufficient affidavit that the judge before whom the matter is pending has a personal bias or prejudice either against him or in favor of any adverse party, such judge 1 United States v. Bremers, 195 F.3d 221, 226 (5th Cir. 1999); see also United States v. Mizell, 88 F.3d 288, 299 (5th Cir. 1996), citing Matter of Hipp, Inc., 5 F.3d 109, 116 (5th Cir. 1993). 2 In re Wilborn, 401 B.R. 848, 860 (Bankr. S.D. Tex. 2009) (citing In re Betts, 143 B.R. 1016, 1022 (Bankr. N.D. Ill. 1992)). 3 See Kinnear–Weed Corp. v. Humble Oil & Refining Co., 441 F.2d 631, 634 (5th Cir. 1971), superseded by statute, 28 U.S.C. § 455 (1974), as stated in Aronson v. Brown, 14 F.3d 1578, 1582-83 (Fed. Cir. 1994) (noting that § 455 was amended in 1974 to, among other things, “omit[ ] the phrase ‘in his opinion’, in order to eliminate the subjective standard.”). 4 K & F Holdings, Ltd. v. Rouse's Enterprises, L.L.C., No. 16-293, 2017 WL 2778345, at *1 (M.D. La. June 27, 2017). shall proceed no further therein, but another judge shall be assigned to hear such proceeding. The affidavit shall state the facts and the reasons for the belief that bias or prejudice exists and shall be filed not less than ten days before the beginning of the term at which the proceeding is to be heard, or good cause shall be shown for failure to file it within such time. A party may file only one such affidavit in any case. It shall be accompanied by a certificate of counsel of record stating that it is made in good faith. This Court has followed other courts in finding that a pro se litigant may not obtain disqualification of a judge under § 144 because a pro se litigant cannot meet the plain language of the statute requiring “a certificate of counsel of record stating that it [the affidavit in support of recusal] is made in good faith.”5 Even if Plaintiff, who is representing himself, could proceed under § 144, he has not met the procedural requirements of that provision.6 Section 455 reads, in pertinent part, as follows: (a) Any justice, judge, or magistrate judge of the United States shall disqualify himself in any proceeding in which his impartiality might reasonably be questioned. (b) He shall also disqualify himself in the following circumstances: (1) Where he has a personal bias or prejudice concerning a party, or personal knowledge of disputed evidentiary facts concerning the proceeding.... In determining whether recusal is appropriate under this statute, the Fifth Circuit has stated that the recusal standard is an objective one. A § 455 claim must not be so broadly construed that “recusal is mandated upon the merest unsubstantiated suggestion of personal bias or prejudice.”7A party seeking recusal must demonstrate that a reasonable and objective person, knowing all the facts and circumstances of the case, would harbor doubts concerning the judge's impartiality.8 This showing must be based on specific facts so as to avoid giving a party a “random veto over the

5 See, e.g., Williams v. Magnolia Cafe, No. 18-1020, 2019 WL 7343507, at *2 (M.D. La. Dec. 31, 2019) (citing Gibson v. Gusman, No. 14-2273, 2014 WL 6469507, at *2 (E.D. La. Nov. 17, 2014)). 6 A § 144 claim must contain a legally sufficient affidavit that “must: (1) state material facts with particularity; (2) state facts that, if true, would convince a reasonable person that a bias exists; and (3) state facts that show the bias is personal, as opposed to judicial, in nature.” Patterson v. Mobil Oil Corp., 335 F.3d 476, 483 (5th Cir. 2003) (citing Henderson v. Dep't of Pub. Safety & Corr., 901 F.2d 1288, 1296 (5th Cir. 1990)). 7 U.S. v. Spears, No. 09-19, 2012 WL 112985, at *2 (M.D. La. Jan. 12, 2012). 8 Patterson, 335 F.3d at 484; Spears, 2012 WL 112985 at * 2. assignment of judges.”9 Furthermore, “the alleged attitude and preconception on the part of the judge must arise from a source beyond the four corners of the courtroom, and not from his participation in the case.”10 “Judicial rulings alone almost never constitute valid basis for a bias or partiality motion.”11 The Fifth Circuit has further noted that a judge's ruling “should constitute grounds for appeal, not for recusal.”12

II. Plaintiff’s Arguments On February 5, 2025, Plaintiff filed a “Judicial Notice” and “Amendment to Motion to Recuse” Judge Shelly Dick and all judges of the Louisiana Middle District.13 There was no original motion filed in this action. This notice/motion requested that all judges in this District be recused from this case “because some have participated and are participating in case numbers above”, citing cases 24-701, 24-934, and the present case.14 Plaintiff asserts that he has “arranged to file a federal suite within other federal jurisdictions… suing the Federal Middle District” on the basis

that “state and federal court district and federal racist and corrupt judges chose their angle of rulings and recommendations to cover/camouflage their civil violations and criminal crimes from the media and public”.15 No such suit has been made known to this Court to date. Plaintiff further alleges that this District’s judges have issued “illegal” rulings and recommendations to destroy Plaintiff’s rights to discovery, due process, and a fair trial.16 Plaintiff asserts that, through their rulings, this District’s white judges are covering racist actions by white

9 Capizzo v. State, No. 99-138, 1999 WL 539439, at * 1 (E.D. La. July 22, 1999). 10 Danielson v. Winnifield Funeral Home of Jefferson, Inc., 634 F. Supp. 1110, 1115 (E.D. La. 1986). 11 United States v. Landerman, 109 F.3d 1053, 1066 (5th Cir. 1997) (citing Liteky v. United States, 510 U.S. 540, 555 (1994)). 12 Id. 13 R. Doc. 34. 14 R. Doc. 34 at 2. 15 R. Doc. 34 at 2. 16 R. Doc. 34 at 2.

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Related

United States v. Mizell
88 F.3d 288 (Fifth Circuit, 1996)
United States v. Landerman
109 F.3d 1053 (Fifth Circuit, 1997)
United States v. Bremers
195 F.3d 221 (Fifth Circuit, 1999)
Patterson v. Mobil Oil Corp.
335 F.3d 476 (Fifth Circuit, 2003)
Liteky v. United States
510 U.S. 540 (Supreme Court, 1994)
In the Matter of Hipp, Inc., Debtor. David Oles
5 F.3d 109 (Fifth Circuit, 1993)
Danielson v. Winnfield Funeral Home of Jefferson, Inc.
634 F. Supp. 1110 (E.D. Louisiana, 1986)