Johnson v. Starwood Hotels & Resorts Worldwide, LLC
- Figueredo
- 1:23-cv-01156
- U.S. District Court · Southern District of New York
- 3
In Johnson v. Starwood, Judge Figueredo denied Johnson’s recusal motion, finding prior rulings did not show bias and declining to schedule trial or hearing.
Joseph Johnson’s request to remove Judge Figueredo and his request for a trial or hearing were denied or deferred; Starwood remained a defendant in the pending case.
What happened
In Johnson v. Starwood Hotels & Resorts Worldwide, LLC, Joseph Johnson asked Magistrate Judge Valerie Figueredo to step aside, claiming she was biased against him. He relied on her earlier decisions denying his request for sanctions and his request for a default judgment against Starwood.
The court explained that a recusal request must provide facts showing that the judge cannot be impartial. A judge’s rulings, by themselves, almost never establish bias. Johnson also asked for a trial or hearing, but a motion to dismiss was still pending and the parties had not completed discovery.
Judge Figueredo denied Johnson’s recusal motion, concluding that he had provided no facts supporting his bias claim. She also said that a trial date could not yet be set and that a hearing was unnecessary at that time. The Clerk was directed to terminate the letter motions requesting recusal and a trial or hearing.
The detailed version
- Johnson v. Starwood Hotels & Resorts Worldwide, LLC · No. 1:23-cv-01156
- Figueredo
- Feb. 4, 2025
Background
On January 29, 2025, Joseph Johnson moved for Magistrate Judge Valerie Figueredo’s recusal, meaning that she should no longer handle the case. Johnson asserted that the judge was biased against him. The court interpreted the request as relying on 28 U.S.C. §§ 455(b)(1) and 144.
Johnson appeared to base his claim on Judge Figueredo’s earlier denial of his motion for sanctions against Starwood and his request for a default judgment. The opinion does not identify any additional facts that Johnson offered to support the bias allegation.
Legal standard and analysis
Section 144 requires a timely and sufficient affidavit stating facts and reasons supporting a claim that the judge has personal bias or prejudice. Section 455(b)(1) requires disqualification when a judge has personal bias or prejudice concerning a party or personal knowledge of disputed evidence-related facts. The court explained that these provisions are interpreted together.
The court held that a party’s disagreement with judicial rulings is generally not enough to establish bias or partiality. Johnson alleged no facts beyond relying on the denials of his sanctions and default-judgment requests. The court therefore concluded that his showing was insufficient under both statutes.
Trial or hearing request
Johnson also requested a trial and/or hearing. The court said that a motion to dismiss remained pending, so the case was not ready for a trial date. It further found that a hearing was unnecessary because the parties had not yet engaged in discovery. The court stated that the District Judge would set a trial date, if necessary, after discovery and any dispositive motions, such as summary-judgment motions, were completed or resolved.
Disposition
Judge Figueredo denied Johnson’s motion for recusal. The court also declined to set a trial date or hold a hearing at that time. The Clerk of Court was directed to terminate the letter motions at ECF Nos. 111 and 114. This opinion addressed recusal and case scheduling; it did not decide the pending motion to dismiss or the underlying claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.