Villars v. Bondi
- Richard Seeborg
- 3:25-cv-04239
- U.S. District Court · Northern District of California
- 3
In Villars v. Bondi, Judge Seeborg denied Villars’s requests for recusal and reconsideration of the earlier dismissal without prejudice.
Janvier Villars; the order leaves the earlier dismissal without prejudice in place while preserving the stated opportunity to file an amended complaint.
What happened
In Villars v. Bondi, Janvier Villars asked Judge Richard Seeborg to step aside and to reconsider an earlier order dismissing his complaint without prejudice. The court said leave to amend had been granted.
Villars argued that the judge’s earlier rulings and his accusations of widespread fraud showed bias. He also sought further proceedings based on the same arguments raised in his complaint and earlier motions.
Judge Seeborg denied both requests. He concluded that disagreement with earlier rulings and unsupported accusations did not justify recusal, and that Villars had not shown a new fact, change in law, or overlooked argument requiring reconsideration.
The detailed version
- Villars v. Bondi · No. 3:25-cv-04239
- Richard Seeborg
- Aug. 1, 2025
Background
Janvier Villars moved to recuse, or disqualify, Judge Richard Seeborg and sought reconsideration of the court’s earlier order dismissing his complaint without prejudice. The court noted that Villars requested relief that does not exist, including review by the full bench of the district and a “blockchain jury.” The earlier dismissal allowed Villars to file an amended complaint.
Recusal and Disqualification
The court denied Villars’s request for recusal and reassignment. It explained that recusal requires circumstances under which a reasonable, well-informed person would question the judge’s impartiality. A judge’s previous adverse ruling is not enough, and any relevant prejudice must come from outside the case. The court found that Villars’s arguments were based on disagreement with prior rulings and broad, unsupported accusations of fraud throughout the judiciary.
The court also denied the request under 28 U.S.C. § 455. It applied the same reasonable-person standard and found that Villars’s allegations did not show that the judge’s impartiality could reasonably be questioned.
Reconsideration
The court stated that local rules generally require a party to obtain permission before filing a reconsideration motion, but it did not deny Villars’s motion for that procedural defect. Instead, it denied the motion because it lacked merit.
Reconsideration is an extraordinary remedy. The court explained that it may be available when there is a material difference in the facts or law, new material facts or a change in law, or a significant failure to consider material facts or decisive legal arguments previously presented. The court found that Villars identified none of those circumstances. His assertions were the same as those in his complaint and earlier motions, and the court had already considered and rejected them as unsupported by the record and his cited authorities.
The court also stated that reconsideration was particularly inappropriate because Villars had been allowed to amend his complaint. It said that any further relief from the earlier dismissal should otherwise be sought through an appeal to the circuit court.
Disposition
Judge Seeborg denied Villars’s motion for recusal and reconsideration. The opinion did not decide the underlying claims in the complaint.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.