Richard Slezak v. State of Hawai‘i, et al.

• Court: District Court, D. Hawaii
• Decided: March 17, 2026
• Docket: 1:25-cv-00287
• Status: Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF HAWAI‘I

RICHARD SLEZAK, Case No. 25-cv-00287-SASP-RT

Plaintiff, ORDER DENYING PLAINTIFF’S MOTION FOR RECUSAL vs.

STATE OF HAWAI‘I, et al.,

Defendants.

On February 25, 2026, pro se Plaintiff Richard Slezak filed a motion seeking the recusal of District Judge Shanlyn A.S. Park. Dkt. No. 54. The Clerk’s Office randomly assigned the motion to this Court for consideration, Dkt. Nos. 55, 56.1 For the reasons discussed below, the motion for recusal is DENIED. Slezak brings his motion for recusal pursuant to 28 U.S.C. § 455(a), which provides that “[a]ny justice, judge, or magistrate judge of the United States shall disqualify himself in any proceeding in which his impartiality might reasonably be questioned.”

1Slezak filed an identical motion in another matter before Judge Park, which was also referred to this Court. See Slezak v. Young Men’s Christian Association of Maui, 25-CV-00272, Dkt. Nos. 93, 97. The substance of that motion is addressed in a separate Order on that docket. Slezak provides a variety of grounds for recusal, all of which are meritless. Dkt. No. 93-1 at 1–2. First, Slezak complains about several decisions made by Judge

Park regarding the admission of evidence or testimony at evidentiary hearings, id. at 3–11, her issuance of an order striking a duplicative motion for temporary restraining order, id. at 10, and her decision to deny Slezak’s motion for preliminary injunction

with prejudice, id. at 12–13. Unfavorable judicial decisions, however, are not proper grounds for recusal under Section 455(a). See United States v. McChesney, 871 F.3d 801, 807 (9th Cir. 2017) (holding that “[j]udicial rulings alone almost never constitute a valid basis for a bias or partiality motion” (internal quotation marks

omitted)); United States v. Holland, 519 F.3d 909, 914–15 (9th Cir. 2008) (holding that Section 455(a) “generally requires as the basis for recusal something other than rulings, opinions formed or statements made by the judge during the course of the

trial”). Slezak may argue that these decisions were issued in error, but a recusal motion is not the appropriate avenue to address those arguments. See Liteky v. United States, 510 U.S. 540, 555 (1994) (holding that disagreements with judicial rulings “are proper grounds for appeal, not for recusal”).

Slezak further argues that Judge Park’s “repeated sanctions warnings” were “conduct that a reasonable person would find troubling.” Dkt. No. 93 at 11–12. Again, adverse judicial decisions are not grounds for recusal, and “troubling”,

whatever that means, is not the appropriate standard by which to measure recusal. See McChesney, 871 F.3d at 807. At any rate, the record reflects that the only warnings against Slezak in this action2 were issued by the Magistrate Judge, not

Judge Park. See, e.g., Dkt. No. 22. Finally, Slezak argues that his grounds “[t]aken together . . . present a cumulative pattern” supporting recusal. Dkt. No. 54-1 at 14. Grounds for recusal

which are individually baseless cannot be added together to make some meritorious whole. See Reed v. Paramo, No. 18-CV-361 (JLS)(DEB), 2023 WL 11992435, at *3 (S.D. Cal. May 15, 2023) (“Not only do [p]laintiff’s individual grounds fail, but, since the whole is not greater than the sum of its parts in this matter, the aggregate

of these grounds also does not provide grounds for disqualification.” (internal quotation marks and alterations omitted)). Just as Slezak’s arguments are unpersuasive individually, they are equally so cumulatively.

“[I]n the absence of a legitimate reason to recuse himself, a judge should participate in cases assigned.” Holland, 519 F.3d at 912 (internal quotation marks omitted). Accordingly, as Slezak provides no legitimate reason as to why Judge Park’s impartiality might “reasonably be questioned” pursuant to Section 455, the

2 In his motion, Slezak refers to warnings issued by Judge Park in his other action. See Slezak, 25- CV-00272, Dkt. Nos. 30, 33, 68. The Court addresses these warnings in a separate Order on that docket. Motion to Recuse, Dkt. No. 54, is denied, and Judge Park will continue to serve as the presiding judge in this action. IT IS SO ORDERED. DATED: March 17, 2026 at Honolulu, Hawai‘1.

dot Derrick K. Watson Rn Chief United States District Judge

Richard Slezak v. State of Hawaii, et al; Civ No 25-00287 SASP-RT; ORDER DENYING PLAINTIFF’S MOTION FOR RECUSAL

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