Rodionova v. Qatar Airways Group
- Donna Ryu
- 3:25-cv-02871
- U.S. District Court · Northern District of California
- 3
In Rodionova v. Qatar Airways, Judge Ryu denied Iana Rodionova’s disqualification motion and her request to seal applications for filing-fee relief.
Self-represented plaintiff Iana Rodionova; the rulings concerned her request to disqualify Judge Donna M. Ryu and her applications to proceed without paying the filing fee. The opinion also names Qatar Airways Group (Q.C.S.C.) and others as defendants.
What happened
In Rodionova v. Qatar Airways Group (Q.C.S.C.), self-represented plaintiff Iana Rodionova asked to disqualify the judge, arguing that the court had acted improperly, prejudged her, and was biased. She cited the court’s refusal to issue summons and its handling of her applications to proceed without paying the filing fee.
The court explained that judicial actions taken during ordinary proceedings generally do not establish legally disqualifying bias. Because Rodionova’s application to proceed without paying the filing fee had been denied and she had not paid the filing fee, the court said it was not required to issue summons. The court also found no reasonable basis to question its impartiality based on the handling of her request to seal those applications.
Judge Donna M. Ryu denied both Rodionova’s motion to disqualify the judge and her motion to seal the applications. The court stated that the California rules Rodionova cited applied to state court, not federal court, and that she provided no other reason for sealing the applications.
The detailed version
- Rodionova v. Qatar Airways Group · No. 3:25-cv-02871
- Donna Ryu
- June 16, 2025
Background
Self-represented plaintiff Iana Rodionova moved under 28 U.S.C. § 455 to disqualify the judge. She alleged violations of court rules and judicial ethics, improper conduct, prejudgment, and bias. Her allegations focused on the court’s refusal to issue summons and its handling of her applications to proceed without paying the filing fee, known as applications to proceed in forma pauperis.
Rodionova had filed a complaint and an application to proceed without paying the filing fee. The court denied that application, and later denied her motions to recover service costs and to reconsider the fee decision. Rodionova then sought disqualification.
Disqualification ruling
Section 455 requires disqualification when a judge’s impartiality might reasonably be questioned or when the judge has personal bias or prejudice concerning a party. The court stated that a disqualification motion must allege an outside-the-proceeding basis for the alleged bias. Actions taken by a judge during the normal course of the case generally are not proper grounds for disqualification.
The court held that its refusal to issue summons was not a basis for disqualification. It had denied Rodionova’s application to proceed without paying the filing fee, and she had not paid the required fee; therefore, the court stated that it had no duty to issue summons. The court also concluded that its failure to treat Rodionova’s statements about confidentiality as a motion to seal did not provide a reasonable basis to question its impartiality. The motion to disqualify was denied.
Sealing ruling
The court liberally interpreted Rodionova’s disqualification motion, in light of her self-represented status, as a late motion to file her applications to proceed without paying the filing fee under seal. The court denied that sealing motion. It explained that the California court rules Rodionova cited apply to California state courts, not federal courts. Rodionova offered no other reason for sealing the applications, and the court found no obvious basis for sealing them from the face of the documents.
Disposition
The court denied Rodionova’s motion to disqualify the judge and denied her motion to seal her applications to proceed without paying the filing fee.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.