Foregger v. Redfin Corporation
- Haywood Gilliam
- 4:24-cv-05701
- U.S. District Court · Northern District of California
- 3
In Foregger v. Redfin, Judge Gilliam denied four requests to disqualify him because Foregger showed no legally sufficient basis.
Christina Foregger and Redfin Corporation were affected by the denial of the disqualification requests; Foregger was also warned about possible filing restrictions and sanctions.
What happened
In Foregger v. Redfin Corporation, pro se plaintiff Christina Foregger filed four requests asking that Judge Haywood Gilliam be removed from her case. The requests did not identify a federal law or rule supporting disqualification.
The court applied standards requiring disqualification when a reasonable, well-informed person could question the judge’s impartiality or when the judge has personal bias. Foregger argued that Judge Gilliam failed to report an attorney for allegedly handling a lawsuit without a California license. The court found that argument insufficient.
Judge Haywood Gilliam denied disqualification. The court warned that further filings repeating the same arguments would not be accepted and that additional frivolous filings could lead to loss of Foregger’s electronic filing privileges or other sanctions.
The detailed version
- Foregger v. Redfin Corporation · No. 4:24-cv-05701
- Haywood Gilliam
- June 30, 2025
Background
Pro se plaintiff Christina Foregger filed four requests to disqualify Judge Haywood Gilliam from presiding over her case against Redfin Corporation. The first request used a California state court complaint form and did not identify a federal statute or rule as the basis for disqualification. The other three requests likewise did not specify a federal basis. The court nevertheless read the requests generously because Foregger was representing herself.
Legal standard
The court explained that judges generally handle the cases assigned to them unless a legitimate reason for disqualification exists. The relevant authorities were 28 U.S.C. §§ 144 and 455 and Canon 3(C) of the Code of Conduct for United States Judges. Under the applicable objective standard, disqualification is required when a reasonable, well-informed person would conclude that the judge’s impartiality might reasonably be questioned. Section 144 also requires a timely and legally sufficient affidavit alleging personal bias or prejudice.
Court’s analysis
The court found that Foregger had not filed the affidavit required for relief under Section 144, so that statute did not apply. It also found that she had not identified facts that could cause a reasonable person to question Judge Gilliam’s impartiality. Foregger’s stated reason was that Judge Gilliam had not reported Taylor Neff, who appears to be an attorney, for allegedly handling a whistleblower lawsuit in California without a California license and attempting to cover up unethical attorneys. The court held that this was not a ground for disqualification under Sections 144 or 455 or Canon 3(C).
Disposition
The court denied disqualification. It also stated that Foregger’s four disqualification requests and two motions to disqualify Redfin’s counsel needlessly multiplied judicial and party resources on claims the court characterized as frivolous. The court warned that further frivolous filings could result in termination of Foregger’s electronic filing privileges and other sanctions. It ordered that no new requests to disqualify Judge Gilliam based on the contentions already stated would be accepted for filing.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.