Bhagat v. Anuja Sharad Shah

Background

The defendant filed an application seeking sanctions against the plaintiff for allegedly continuing not to comply with two earlier docket orders. The defendant also asked Magistrate Judge Robyn F. Tarnofsky to be reassigned or to recuse herself, meaning to step aside because of a claimed concern about impartiality. The case had been referred to Judge Tarnofsky for general pretrial supervision and decisions on motions that could resolve the case.

Judge Tarnofsky ordered the plaintiff to provide the defendant’s counsel with a copy of documents in a file sent to counsel for Dordi in state-court litigation. She also ordered the plaintiff to respond to the defendant’s sanctions application by October 21, 2025.

Legal standard

Under 28 U.S.C. § 455(a), a federal judge must step aside when the judge’s impartiality might reasonably be questioned. The court applied an objective test: whether a fully informed, reasonable observer would have significant doubt that justice would be done without recusal. The court explained that a judge’s rulings, standing alone, almost never establish a valid basis for recusal, and that dissatisfaction with unfavorable decisions generally should be addressed through objections to those decisions.

Ruling

Judge Tarnofsky denied the application for her recusal. She found that the defendant’s dissatisfaction with her recommendations and rulings did not provide a sufficient factual basis to show bias. The order stated that the parties could challenge her rulings by filing objections with Judge Valerie Caproni, and that objections—not recusal requests—were the appropriate response to unfavorable decisions. The opinion does not state a final disposition of the defendant’s sanctions application.