Thompson v. Equifax

Background

Kenan Thompson, proceeding without a lawyer, moved under 28 U.S.C. § 455 to disqualify the magistrate judge handling discovery. The motion followed several rulings denying Thompson’s requests to appear remotely at an August 7, 2025 discovery hearing. The magistrate judge had found that Thompson did not show good cause for remote attendance and later denied related requests for reconsideration and emergency relief.

Thompson did not attend the August 7 hearing. The magistrate judge later issued an order requiring Thompson to explain his nonappearance and failure to comply with court orders. Thompson’s filings repeatedly asserted financial hardship but, according to the order, did not include documents such as bank statements or other financial records supporting his inability to travel. The order also noted that Thompson had stated he owned a car and lived without rent or monthly utility obligations.

Legal standard and analysis

Under Sections 144 and 455, disqualification is appropriate when a reasonable person who knows all the facts would reasonably question the judge’s impartiality. The court explained that recusal can be based on actual bias or the appearance of bias. It also applied Civil Local Rule 3-14, which requires referral of a disqualification request to another judge in certain circumstances unless the request is legally insufficient or filed for delay.

The court concluded that Thompson’s motion did not identify actual bias or an appearance of bias. It reasoned that adverse rulings, including denying requests for remote attendance, do not by themselves show bias. The court also rejected Thompson’s arguments concerning statements made at the August 7 hearing, explaining that he had chosen not to attend and that the hearing involved no substantive argument from him.

The court further held that deciding the discovery disputes on the written submissions was not grounds for disqualification because the local rules permit resolving motions without oral argument. It found that Thompson’s motion was legally insufficient and interposed for delay, particularly because he filed a motion to stay proceedings based on the pending disqualification request.

Disposition

The court found that referral of the disqualification motion was not warranted under Civil Local Rule 3-14. It denied Thompson’s motion to disqualify with prejudice and stated that the ruling resolved Docket 84. The case information identifies Vince Chhabria as the judge, but the order’s signature identifies only an unnamed magistrate judge.

Note on the opinion text

The opinion text does not clearly identify the name of the magistrate judge who issued the order. It does identify Judge Chhabria as the judge who previously denied Thompson’s objections.