Dawson v. Napa County
- Jacquelyn Corley
- 3:25-cv-01923
- U.S. District Court · Northern District of California
- 4
In Dawson v. Napa County, Judge Corley denied Dawson’s motion to disqualify her based on reassignment, adverse rulings, and alleged prior patterns.
Amanda Jeane Dawson’s motion to disqualify Judge Jacqueline Scott Corley.
What happened
In Dawson v. Napa County, Amanda Jeane Dawson asked Judge Jacqueline Scott Corley to disqualify herself after the case was reassigned to her and she denied Dawson’s request for emergency temporary and other immediate court orders.
The court explained that reassignment and decisions a party dislikes generally do not show bias. It found that Dawson did not identify facts showing bias from outside the case or that a reasonable person would question the judge’s impartiality.
Judge Jacqueline Scott Corley denied Dawson’s motion to disqualify. The order states that it disposes of Docket No. 19.
The detailed version
- Dawson v. Napa County · No. 3:25-cv-01923
- Jacquelyn Corley
- May 27, 2025
Background
Amanda Jeane Dawson moved under 28 U.S.C. §§ 144 and 455(a) to disqualify Judge Jacqueline Scott Corley. She based the motion on the reassignment of the case from a magistrate judge, the court’s denial of her request for a temporary restraining order and other injunctive relief, and what she described as the judge’s pattern of denying equitable relief to people representing themselves in civil-rights cases and making controversial decisions involving institutional parties.
Legal standard
The court explained that a judge must step aside when a reasonable person who knew all the facts would reasonably question the judge’s impartiality, or when the judge has personal bias or prejudice concerning a party. A motion under Section 144 must also include a timely and legally sufficient sworn statement identifying facts supporting alleged bias. The court stated that bias generally must come from an outside source rather than from the judge’s rulings, opinions, or statements made during the case. Adverse rulings and critical comments ordinarily are not enough.
Court’s analysis
The court found that the reassignment was not evidence of bias because the docket showed that the case was randomly assigned to the district judge either because a party had not consented to a magistrate judge’s jurisdiction or because a pending matter required a prompt decision before the necessary consents were obtained.
The court also rejected Dawson’s reliance on the denial of emergency relief. It stated that an adverse ruling is not an adequate basis for disqualification. The court noted that its order, issued two days after Dawson filed her temporary-restraining-order motion, explained that federal courts could not stop the pending state criminal and child-custody proceedings at issue under binding Supreme Court and Ninth Circuit precedent.
Finally, the court found that Dawson identified only one prior case involving the judge, a merger in the video-gaming industry, and did not explain how the judge’s prior rulings showed bias in this case. The court concluded that Dawson had not alleged specific facts showing bias or prejudice from an outside source and had not shown that a reasonable person would question the judge’s impartiality.
Disposition
The court denied Dawson’s motion for disqualification. The order states that it disposes of Docket No. 19.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.