Arnold v. DeJoy
- Gregory Woods
- 1:24-cv-04814
- U.S. District Court · Southern District of New York
- 4
In Sheon Arnold v. Louis DeJoy, Magistrate Judge Netburn denied Arnold’s request to disqualify her, finding scheduling extensions did not show bias.
The ruling directly affected Sheon Arnold’s request to disqualify Magistrate Judge Sarah Netburn based on alleged bias arising from scheduling extensions.
What happened
In Sheon Arnold v. Louis DeJoy, Sheon Arnold, who represented himself, complained that the court had granted too many deadline extensions, causing unnecessary delays. Although he did not expressly request recusal, the court treated his complaint as a request to disqualify the magistrate judge.
The court explained that disqualification requires facts that would cause an objective observer to reasonably question the judge’s impartiality. It found no such facts. The court had granted five extensions over about a year, including extensions for both sides, and had also given Arnold additional time and accepted his late opposition brief.
Magistrate Judge Sarah Netburn denied Arnold’s motion. She stated that scheduling decisions and a party’s disagreement with the judge’s rulings generally do not establish bias or partiality, and she found no personal bias or prejudice against Arnold.
The detailed version
- Arnold v. DeJoy · No. 1:24-cv-04814
- Gregory Woods
- Sept. 16, 2025
Background
On August 26, 2025, pro se Plaintiff Sheon Arnold filed a “Complaint of Judicial Misconduct and Disability.” He alleged that the court had granted “too many extensions,” that the extensions questioned the court’s motive, and that they caused unnecessary and unreasonable delays. Arnold did not expressly move for recusal, but Magistrate Judge Sarah Netburn treated the filing as a motion for recusal, meaning a request that the judge disqualify herself.
Legal standard
The court applied 28 U.S.C. § 455. Under that statute, a judge must disqualify herself when her impartiality might reasonably be questioned or when she has personal bias or prejudice concerning a party. The standard asks whether an objective, disinterested observer fully informed of the facts would have significant doubt that justice could be done without recusal. The court emphasized that judges are presumed impartial and that the party seeking recusal bears a substantial burden. If the standard is not met, disqualification is prohibited rather than optional.
Analysis
The court found Arnold’s judicial-misconduct claim unwarranted. Over approximately one year, it had granted five extensions. Four followed requests by Defendants and each sought no more than 30 additional days. After the last extension, Defendants were told that no further extensions would be granted.
The court also noted that it had granted Arnold’s request for more time to oppose Defendants’ motion to dismiss and for summary judgment, giving him approximately five additional weeks. Even after Arnold missed that extended deadline, the court accepted his opposition brief, which was filed almost two weeks late. The court viewed these actions as accommodations to both sides, not evidence of bias or partiality.
The court further stated that scheduling decisions generally are not a valid basis for recusal and that a litigant’s disagreement with a judge’s rulings almost never establishes bias or partiality. Netburn also stated that she had no personal bias or prejudice concerning Arnold and that Arnold had not explained why her impartiality could reasonably be questioned.
Disposition
Magistrate Judge Sarah Netburn denied Arnold’s motion for recusal.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.