Williams v. NYC Board of Elections

Background

Carman Williams filed a second motion asking U.S. Magistrate Judge Katharine H. Parker to recuse herself under 28 U.S.C. § 455(a). Recusal means a judge steps aside from a case because of possible bias or because the judge’s impartiality might reasonably be questioned.

Williams relied on several rulings and actions during the case: the denial of her request to extend discovery, the denial of her request for electronically stored information, limits on additional document requests, an order setting a date for her deposition, and an admonishment for calling defense counsel an “Uncle Tom.” Williams also speculated that race was a factor in the court’s decisions and noted that nearly all defendants and the judge were white.

Court’s analysis

The court explained that a judge is presumed to be impartial and that the person seeking recusal bears a substantial burden. Disqualifying bias generally must come from an outside source rather than from the judge’s participation in the case. Opinions formed from facts or events in the current or earlier proceedings ordinarily do not establish bias unless they show such deep favoritism or hostility that fair judgment would be impossible.

The court stated that Williams offered no allegation or evidence of bias from an outside source. It also stated that the challenged rulings were discovery rulings made under the applicable rules of civil procedure and therefore could not serve as the basis for recusal. The court expressly disclaimed any bias or prejudice and stated that race had no bearing on its decisions.

Disposition

Judge Katharine H. Parker denied the motion to recuse. The Clerk of Court was directed to mail Williams a copy of the order and terminate the motion at ECF No. 98 as denied.