Acosta v. Related Management Companies
- Katherine Failla
- 1:23-cv-10292
- U.S. District Court · Southern District of New York
- 3
In Michael Anthony Acosta v. Related Management, Judge Failla denied Acosta’s motion to recuse herself, finding no bias or reason requiring disqualification.
Michael Anthony Acosta and the presiding judge in the case; the underlying case remained before the same judge after the motion was denied.
What happened
In Michael Anthony Acosta v. Related Management Companies, Michael Anthony Acosta, representing himself, asked the court to remove the presiding judge from his case. He argued that the judge was biased, had treated his claims and religious beliefs dismissively, and had failed to consider important facts and misconduct by the defendants.
The court explained that unfavorable rulings and critical comments generally do not prove bias. It said Acosta had not shown that the judge’s views came from information outside the case or that the judge’s conduct made fair judgment impossible.
Judge Katherine Failla denied Acosta’s motion because the legal standards for disqualification were not met. The clerk was directed to close the pending motion and mail Acosta a copy of the court’s decision.
The detailed version
- Acosta v. Related Management Companies · No. 1:23-cv-10292
- Katherine Failla
- Sept. 24, 2025
Background
Michael Anthony Acosta, who was representing himself, moved under 28 U.S.C. § 455 to disqualify the presiding judge. He alleged actual bias, the appearance of impropriety, denial of due process, and lack of judicial impartiality. His motion asserted that the court had repeatedly dismissed meritorious claims, minimized his medical hardship, threatened sanctions or counterclaims, disregarded constitutional and statutory claims, ignored material facts, failed to sanction alleged misconduct by the defendants, and made dismissive remarks about his religious beliefs. He asked the court to remove the judge, reconsider rulings under Federal Rule of Civil Procedure 60(b)(6), and reassign the case.
Court’s Analysis
The court rejected Acosta’s arguments. It explained that rulings against a party are not, by themselves, evidence of bias or prejudice requiring recusal. It also relied on the rule that judicial comments criticizing or disapproving of a party or the party’s case ordinarily do not establish bias unless they show an opinion based on information outside the case or such extreme favoritism or hostility that fair judgment would be impossible. The court found that Acosta had identified no outside source for the alleged bias and had not shown that fair judgment was impossible. It concluded that he had not established personal bias against him or favoritism toward an opposing party under 28 U.S.C. § 144.
Ruling and Effect
Judge Katherine Failla denied Acosta’s motion to recuse. The court stated that because the disqualification standards were not met, disqualification was prohibited, and it directed the clerk to terminate the pending motion at docket entry 46 and mail a copy of the endorsement to Acosta at his address of record. The opinion did not grant the requested reassignment or reconsideration relief.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.