Seifert v. Pritchard

District Court, E.D. California·Decided May 27, 2025·No. 1:24-cv-01097·Unknown

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 ALEXANDRA SEIFERT, Case No.: 1:24-cv-01097-KES-CDB 12 Plaintiff, ORDER DENYING PLAINTIFF’S MOTION AND AMENDED MOTION FOR RECUSAL 13 v. AND DISQUALIFICATION

14 KENNETH GEORGE PRITCHARD, et al., (Docs. 26, 28)

15 Defendants.

16 17 Plaintiff Alexandra Seifert is proceeding pro se and in forma pauperis in this action 18 brought pursuant to 18 U.S.C. §§ 241 and 242, 18 U.S.C. § 1018, 28 U.S.C. § 454, 42 U.S.C. §§ 19 1983 and 1985. (Doc. 1). Pending before the Court is Plaintiff’s motion for recusal and 20 disqualification of the undersigned, filed on April 29, 2025. (Doc. 26). Plaintiff filed an amended 21 motion on May 19, 2025. (Doc. 28). 22 I. Governing Law 23 A. Recusal 24 28 U.S.C. § 144 provides: 25 Whenever a party to any proceeding in a district court makes and files a timely and sufficient affidavit that the judge before whom the 26 matter is pending has a personal bias or prejudice either against him or in favor of any adverse party, such judge shall proceed no further 27 therein, but another judge shall be assigned to hear such proceeding. 1 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 2 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 3 accompanied by a certificate of counsel of record stating that it is made in good faith. 4 5 28 U.S.C. § 144. 6 The standard for recusal under section 144 is “‘whether a reasonable person with 7 knowledge of all the facts would conclude that the judge’s impartiality might reasonably be 8 questioned.’” Mayes v. Leipziger, 729 F.2d 605, 607 (9th Cir. 1984) (quoting United States v. 9 Nelson, 718 F.2d 315, 321 (9th Cir.1983)). To provide adequate grounds for recusal, prejudice 10 must result from an extrajudicial source since a judge’s previous adverse ruling alone is not 11 sufficient for recusal. Id. 12 Section 144 expressly conditions relief upon the filing of a timely and legally sufficient 13 affidavit. A judge who finds the affidavit legally sufficient must proceed no further under section 14 144 and must assign a different judge to hear the matter. See 28 U.S.C. § 144; United States v. 15 Sibla, 624 F.2d 864, 867 (9th Cir. 1980). On the other hand, where the affidavit is not legally 16 sufficient, the judge to whom the motion is directed can determine the matter. See United States v. 17 Scholl, 166 F.3d 964, 977 (9th Cir. 1999) (citing Toth v. Trans World Airlines, Inc., 862 F.2d 18 1381, 1388 (9th Cir. 1988) (holding that only after determining the legal sufficiency of a § 144 19 affidavit is a judge obligated to reassign decision on merits to another judge)). If the affidavit is 20 legally insufficient, then recusal can be denied. See United States v. $292,888.04 in U.S. 21 Currency, 54 F.3d 564, 566 (9th Cir. 1995). 22 B. Disqualification 23 28 U.S.C. § 455, concerning judicial disqualification, provides, in relevant part, as 24 follows: 25 (a) Any justice, judge, or magistrate judge of the United States shall disqualify himself in any proceeding in which his impartiality 26 might reasonably be questioned. 27 (b) He shall also disqualify himself in the following circumstances: (1) Where he has a personal bias or prejudice concerning a party, 1 concerning the proceeding; … 2 28 U.S.C. § 455(a), (b)(1). 3 “The purpose of § 455 is ‘to avoid even the appearance of partiality.” United States v. 4 Baca, 610 F. Supp.2d 1203, 1211 (E.D. Cal. 2009) (citation omitted). Although a judge must 5 recuse himself from any proceeding in which any of the section 455 criteria apply, he or she must 6 not simply recuse out of an abundance of caution when the facts do not warrant recusal. Instead, 7 there is an equally compelling obligation not to recuse where recusal in not appropriate. See 8 United States v. Holland, 519 F.3d 909, 912 (9th Cir. 2008) (“We are as bound to recuse 9 ourselves when the law and facts require as we are to hear cases when there is no reasonable 10 factual basis for recusal”). The standard for recusal under section 455 is whether a reasonable 11 person with knowledge of all the facts would conclude that the judge’s impartiality might 12 reasonably be questioned. Perry v. Schwarzenegger, 630 F.3d 909, 911 (9th Cir. 2011). “The 13 obligation not to recuse is perhaps at its highest when the motion has been brought after the party 14 seeking recusal has sustained an adverse ruling during the action.” United States v. Sierra Pac. 15 Indus., 759 F. Supp.2d 1198, 1205-06 (E.D. Cal. 2010). 16 The decision regarding disqualification is to be made by the judge whose impartiality is at 17 issue. In re Bernard, 31 F.3d 842, 843 (9th Cir. 1994) (holding that a motion for recusal must be 18 decided by the very judge whose impartiality is being questioned); United States v. Studley, 783 19 F.2d 934, 940 (9th Cir. 1986) (same). 20 II. Discussion 21 A. Recusal under Section 144 22 Upon review of Plaintiff’s motion for recusal and disqualification, the undersigned finds it 23 to be insufficient. It fails to allege facts that would support the contention that the undersigned has 24 exhibited bias and prejudice directed towards Plaintiff from an extrajudicial source, i.e., outside 25 of his rulings on this case. See Sibla, 624 F.2d at 868 (“An affidavit filed pursuant to [§ 144] is 26 not legally sufficient unless it specifically alleges facts that fairly support the contention that the 27 judge exhibits bias or prejudice directed toward a party that stems from an extrajudicial source.”). Rather, Plaintiff’s motion alleges bias or prejudice arising solely out of judicial actions taken by 1 the undersigned, namely: (1) the undersigned’s findings and recommendations, issued on 2 November 15, 2024 (Doc. 8), and March 7, 2025 (Doc.

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