Robert Pizzimenti v. City of Detroit, et al.

CourtDistrict Court, E.D. Michigan
DecidedMarch 27, 2026
Docket5:25-cv-11506
StatusUnknown

This text of Robert Pizzimenti v. City of Detroit, et al. (Robert Pizzimenti v. City of Detroit, et al.) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robert Pizzimenti v. City of Detroit, et al., (E.D. Mich. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Robert Pizzimenti,

Plaintiff, Case No. 25-11506

v. Judith E. Levy United States District Judge City of Detroit, et al., Mag. Judge Curtis Ivy, Jr. Defendants.

________________________________/

ORDER ADOPTING THE REPORTS AND RECOMMENDATIONS [27, 28] AND OVERRULING OBJECTIONS TO THE ORDER DENYING PLAINTIFF’S MOTION FOR RECUSAL AND DISQUALIFICATION [26]

Before the Court is Magistrate Judge Curtis Ivy, Jr.’s Reports and Recommendations (“R&Rs”) recommending the Court grant Defendants City of Detroit, Conrad Mallet, Jr., Tamara York Cook, and Kelly Larson’s motion to dismiss and dismiss the remaining John Doe defendants (ECF No. 28), and deny Plaintiff’s motion to recuse the undersigned. (ECF No. 27.) Judge Ivy also issued an order denying Plaintiff’s motion to recuse Judge Ivy and to disqualify Defendants’ counsel. (ECF No. 26.) Plaintiff Robert Pizzimenti filed objections to Judge Ivy’s R&Rs

and the order. (ECF No. 29.) Defendants filed a response to Plaintiff’s objection (ECF No. 30.) For the reasons set forth below, the reports and recommendations

(ECF Nos. 27, 28) are adopted, Plaintiff’s objections (ECF No. 29) are overruled, and the case is dismissed. I. Background

The factual and procedural backgrounds set forth in the R&Rs are fully adopted as though set forth in this Opinion and Order. (See ECF No. 27, PageID.202–204; ECF No. 28, PageID.212–215.)

II. Plaintiff’s objections to the R&R and order regarding Plaintiff’s motion to recuse (ECF Nos. 26, 27) On September 11, 2025, Plaintiff filed a “motion to recuse District Judge Judith E. Levy and Magistrate Judge Curtis Ivy, Jr., and to disqualify taxpayer-funded defense for Defendants Conrad Mallett, Jr.

and Tamara York-Cook.” (ECF No. 20.) Judge Ivy issued an order regarding the motion to recuse Judge Ivy and to “disqualify” Defendants Mallett and Cook’s counsel (ECF No. 26), and an R&R regarding the

motion to recuse the undersigned. (ECF No. 27.) A. R&R recommending that Plaintiff’s motion to recuse the undersigned be denied (ECF No. 27) Judge Ivy recommends in an R&R that Plaintiff’s motion to recuse

the undersigned be denied. (ECF No. 27.) The parties were required to file specific written objections to that order, if any, within 14 days of service. Fed. R. Civ. P. 72(b)(2); E.D. Mich. L.R. 72.1(d).

No objections were filed as to this R&R.1 The Court has nevertheless carefully reviewed the R&R and concurs in the reasoning and result. The R&R recommending that Plaintiff’s motion to recuse the

undersigned is adopted and Plaintiff’s motion to recuse the undersigned is denied. B. Order denying Plaintiff’s motion to recuse Judge Ivy and to disqualify counsel (ECF No. 26) Judge Ivy issued an order (ECF No. 26) denying Plaintiff’s motion

(ECF No. 20) to recuse himself and to disqualify Defendants Mallett and Cook’s counsel. Plaintiff filed one objection to Judge Ivy’s order that addresses the order denying Plaintiff’s motion to disqualify Mallett and

Cook’s counsel. (ECF No. 29, PageID.256–257.)

1 Plaintiff’s objections (ECF No. 29) do not address this R&R. i. Legal Standard

Federal Rule of Civil Procedure 72(a) provides that, for non- dispositive pretrial matters where a magistrate judge issues a written order:

[a] party may serve and file objections to the order within 14 days after being served with a copy. A party may not assign as error a defect in the order not timely objected to. The district judge in the case must consider timely objections and modify or set aside any part of the order that is clearly erroneous or is contrary to law. Fed. R. Civ. P. 72(a). The Eastern District of Michigan Local Rules state that objections under Rule 72 “must: (A) specify the part of the order . . . to which a person objects; and (B) state the basis for the objections.” E.D. Mich. LR 72(d). ii. Analysis Plaintiff’s objection is overruled because he has not demonstrated

that Judge Ivy’s order “is clearly erroneous or is contrary to law.” Fed. R. Civ. P. 72(a).

Plaintiff moved to disqualify Mallett and Cook’s counsel, who are attorneys from the City of Detroit Law Department. (ECF No. 20, PageID.166–167.) Plaintiff believes that Mallett and Cook are not eligible for government agency-funded counsel under Mich. Comp. Laws

§ 691.1408(1) because Mallett and Cook are being sued for “acts outside their official scope.” (Id.) Judge Ivy denied this motion on the basis that Plaintiff did not

provide sufficient legal basis for disqualification, because Plaintiff “conflates immunity to liability with one’s ability to receive government agency-funded counsel under Michigan state law.” (ECF No. 26,

PageID.198.) While it is true that a prosecutor may not have absolute prosecutorial immunity for certain acts, such as statements at a press conference, “Plaintiff has not shown that § 691.1408(1) relies on the

same type of inquiry” as prosecutorial immunity. (Id.) Additionally, Judge Ivy reasoned that, “[i]f an official was alleged to have broken the law and could not receive government-funded counsel based on the

allegations alone, there would be no reason for § 691.1408(1) to exist in the first place.” (Id.) Plaintiff’s objection to this order asserts that Judge Ivy’s order

was incorrect because “[s]cope-of-authority determinations are fact- dependent” and, as such, the order resolved Mallett and Cook’s scope of authority issues “prematurely.” (ECF No. 29, PageID.257.) This objection is insufficient. First, Plaintiff provides no legal

support for this objection, such as that a “scope-of-authority” determination under § 691.1408(1) requires “factual development.” (ECF No. 29, PageID.257.)

Second, the Court supplements Judge Ivy’s reasoning and holds that Plaintiff does not sufficiently demonstrate the Court’s authority to disqualify Mallett and Cook’s counsel under Mich. Comp. Laws §

691.1408. The Court’s authority to disqualify counsel is not unlimited. Generally, federal courts may only disqualify counsel on the basis of a

conflict of interest or unethical behavior by counsel. See Wellman v. Supreme Ct. of Ohio, No. 18-3260, 2018 WL 9651499, at *1 (6th Cir. Nov. 13, 2018) (“A court should only disqualify an attorney ‘when there

is a reasonable possibility that some specifically identifiable impropriety’ [by the attorney] actually occurred.”). Plaintiff does not claim that Defendants’ counsel—Patrick M. Cunningham—has done

anything unethical. Though Plaintiff suggests that Defendants’ counsel should not represent Mallett because “Mallett exercises direct or indirect oversight over the legal defense strategies of city employees and official including those now representing him and . . . Tamara York-

Cook” (ECF No. 20, PageID.159), Plaintiff does not explain why this warrants Defendants’ counsel’s disqualification from the case. Clients may oversee the legal strategy of their counsel.

Plaintiff also argues that the Court should disqualify Mallett and Cook’s counsel on the basis that Mallett and Cook’s alleged actions are not within the scope of activities in which Mich. Comp. Laws §

691.1408(1) permits indemnification or payment of legal expenses. But Plaintiff does not explain how § 691.1408(1) gives the Court power to disqualify counsel. The Court is unable to find a case in which a court—

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