Pasha v. New York State Department of Health

Background

Talha Pasha, representing himself, brought 17 claims against the New York State Department of Health, the ExecuSearch Group, and Anida Shyti. He alleged discrimination based on his Asian race, Islamic religion, and Pakistani national origin, as well as harassment, a hostile work environment, retaliation, and wrongful termination. The opinion states that he asserted claims under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, and the New York State Human Rights Law.

On February 10, 2025, Pasha filed four letters asking that all communications among the parties be directed to the court. The court denied that request on February 11, explaining that the parties would communicate directly with one another during ordinary pretrial matters. Pasha then moved for Judge Ramos’s recusal, meaning that he asked the judge to step aside from the case. He based the motion on the February 11 order and argued that the court’s failure to address an accusation that he was “blatantly sexist” demonstrated bias.

Positions on the Motion

The ExecuSearch Group and Shyti took no formal position on the motion but stated that they saw no basis for recusal and believed recusal would further delay the case. The New York State Department of Health opposed the motion and argued that no reasonable person would conclude that the court had acted impartially toward Pasha.

Legal Standard

Under 28 U.S.C. § 455(a), a judge must step aside when the judge’s impartiality might reasonably be questioned. The court explained that recusal is assessed objectively: the question is whether a reasonable, fully informed person would have significant doubt that justice would be done without recusal. A strong presumption of judicial impartiality applies, and the person seeking recusal carries a substantial burden. The court also stated that judicial rulings almost never provide a valid basis for a bias or partiality motion.

Court’s Analysis and Ruling

Judge Ramos found that Pasha had not alleged facts suggesting that the court’s impartiality could reasonably be questioned. The court concluded that Pasha’s accusations of bias were unsupported and that he had not identified conduct “so extreme as to display clear inability to render fair judgment.” Because the court found no legitimate basis for recusal, it denied the motion for recusal.

The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal of the order would not be taken in good faith. It therefore denied Pasha permission to appeal without paying filing fees. The clerk was directed to terminate the recusal motion.