Mattingly v. Justice
- Edward Chen
- 3:24-cv-03061
- U.S. District Court · Northern District of California
- 2
In Mattingly v. Justice, Judge Edward Chen denied the defendant’s request to reconsider remand and explained that prior adverse rulings did not establish bias.
The defendant/counter-plaintiff, Hillary Carlvin Justice, whose request to reconsider the remand order was denied. The case remains closed, and further filings require the court’s permission and a showing of good cause.
What happened
Mattingly v. Justice involved a filing by the defendant/counter-plaintiff seeking the “impeachment” of Judge Edward Chen under several federal statutes and rules. The filing also referred to correcting an earlier court ruling.
The court treated the filing, in part, as a possible request to disqualify Judge Chen and, in part, as a request to reconsider the court’s remand order. It explained that earlier unfavorable rulings generally do not establish judicial bias.
Judge Edward Chen denied the request to reconsider the remand order, stating that the case had no original federal subject-matter jurisdiction. The court also said the case was closed and that any further filing required permission and a showing of good cause.
The detailed version
- Mattingly v. Justice · No. 3:24-cv-03061
- Edward Chen
- Sept. 12, 2024
Background
The defendant/counter-plaintiff filed a document titled a motion for “impeachment” of United States District Judge Edward Chen. The filing cited Federal Rules of Civil Procedure 55(b)(D) and 60(d)(3), 28 U.S.C. §§ 455, 1441(a), and 2283, and referred to submitting a request for Judge Chen’s impeachment to Senator Laphonza Butler.
Because of the filing’s caption and contents, the court said it seemed unlikely that the defendant was seeking relief from Judge Chen. The court nevertheless addressed the filing’s main arguments.
Disqualification and reconsideration
The court explained that, to the extent the defendant sought Judge Chen’s disqualification, judicial rulings alone almost never establish bias or partiality. An unfavorable ruling is not by itself enough to require disqualification, and the court described the filing as essentially relying on prior adverse rulings.
The court also treated the filing as possibly seeking reconsideration of its earlier remand order. It rejected the defendant’s reliance on a cited case, explaining that the case was not comparable. The court stated that supplemental jurisdiction under 28 U.S.C. § 1367 requires original subject-matter jurisdiction over at least one claim first. The court reiterated that, in this case, there was no original federal subject-matter jurisdiction.
Disposition
The court denied the request for relief to the extent the defendant sought reconsideration of the remand order. The court also stated that the case was closed. It directed that any further filing must be submitted with a request for permission and a showing of good cause; otherwise, the filing would be stricken.
Judge Edward Chen signed the order on September 12, 2024.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.