Sweigert v. Goodman
- John Koeltl
- 1:23-cv-05875
- U.S. District Court · Southern District of New York
- 4
In Sweigert v. Goodman, Judge Figueredo denied Goodman’s recusal motion, finding his complaints about case management did not show bias.
Jason Goodman’s request to have Magistrate Judge Valerie Figueredo removed from the case was denied. The case remained before Judge Figueredo, and Goodman’s separate restraining-order motion remained pending.
What happened
In Sweigert v. Goodman, Jason Goodman asked Magistrate Judge Valerie Figueredo to step aside, claiming she was biased against him.
Goodman pointed to the Court’s handling of a December 2024 conference, its rescheduling of a future conference, and its failure to rule yet on his request to restrict D.G. Sweigert’s conduct. The opinion says the request to restrict conduct remains pending.
Judge Figueredo denied the recusal motion because Goodman provided no facts showing bias; dissatisfaction with scheduling and other case-management decisions was not enough. The Clerk was directed to terminate the motion, and a hearing remained scheduled for April 1, 2025.
The detailed version
- Sweigert v. Goodman · No. 1:23-cv-05875
- John Koeltl
- Feb. 19, 2025
Background
Jason Goodman moved under 28 U.S.C. §§ 144 and 455 for Magistrate Judge Valerie Figueredo to recuse herself, meaning to step aside from the case. Goodman alleged that the judge had shown bias against him and had failed to ensure fair and orderly proceedings.
Goodman relied on the Court’s administration of a December 18, 2024 conference, the rescheduling of a conference for April 1, 2025, and the Court’s failure to rule yet on his motion for a restraining order. He argued that these events showed the Court had accepted D.G. Sweigert’s assertion that attending an earlier conference in person would create financial hardship.
Court’s Analysis
The Court explained that a recusal motion must provide facts supporting a reasonable claim that the judge has a personal bias or prejudice, or personal knowledge of disputed facts. The standards under Sections 144 and 455(b)(1) are treated together, so failure to establish grounds under Section 455 also defeats relief under Section 144.
The Court concluded that Goodman’s complaints about scheduling and the handling of the December conference were conclusory and did not identify facts showing bias. Judicial case management and rulings generally are not enough to support recusal merely because a litigant is dissatisfied with them.
The Court also stated that Goodman’s restraining-order motion remained pending and would be addressed in due course. The opinion described that motion as apparently seeking a permanent injunction restricting Sweigert from contacting Goodman, his family members, and associates, and from filing complaints about Goodman with social-media platforms. The Court noted that injunctions restricting speech are disfavored, but it did not decide the restraining-order motion in this order.
Disposition
Judge Valerie Figueredo denied Goodman’s motion for recusal. The Clerk of Court was directed to terminate the motion at ECF No. 227. The opinion stated that a hearing on the parties’ outstanding disputes was scheduled for April 1, 2025.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.