Wright v. United States of America
- Charles Breyer
- 3:14-cv-03008
- U.S. District Court · Northern District of California
- 3
In Wright v. United States, Judge Breyer denied Wright’s motion to disqualify him, finding dissatisfaction with rulings did not show bias.
Linda Ann Wright and the judge assigned to her long-closed case; the ruling also set a warning about possible sanctions for future baseless filings.
What happened
In Wright v. United States of America, Linda Ann Wright asked the judge to step aside from her long-closed case. She challenged the court’s description of her claims and its warning about possible sanctions.
The court said Wright’s complaints reflected frustration with losing her lawsuit and with results in other cases, not personal bias or hostility by the judge. It also found her request legally insufficient, so it did not send the request to another judge for review.
Judge Charles R. Breyer denied the motion to disqualify. He declined to sanction Wright at that time but instructed her that another motion without a legal or factual basis would result in sanctions.
The detailed version
- Wright v. United States of America · No. 3:14-cv-03008
- Charles Breyer
- Mar. 8, 2021
Background
The court had dismissed Linda Ann Wright’s complaint in 2015 and entered judgment for the defendants. The Court of Appeals later affirmed, describing Wright’s amended complaint as largely unintelligible and lacking factual specificity. In January and February 2021, the court denied two motions by Wright to reopen the case. The court found the first motion untimely and unsupported by any basis to conclude that the judgment was void, and found that the second motion did not materially differ from the first. The court warned that repeated frivolous filings could lead to sanctions under Rule 11 of the Federal Rules of Civil Procedure.
Wright then moved to disqualify the judge. She objected to the characterization of her claims, referred to a possible clerical error, denied that she had ever filed a frivolous matter, and asserted that the litigation involved an umbrella protecting lawlessness and criminality against her and her family.
Legal standard
Under 28 U.S.C. §§ 144 and 455, disqualification may be required when a reasonable person who knows the relevant facts would reasonably question the judge’s impartiality. The standard covers both actual bias and the appearance of bias. A local rule also provides a procedure for referring a legally sufficient affidavit of bias to another judge when the judge declines to recuse.
Court’s reasoning
The court concluded that Wright’s grievances did not justify disqualification. It found that her complaints arose from dissatisfaction with the unsuccessful lawsuit and the lack of a legal basis to reopen it. Her frustration also concerned other cases that were not before this judge. The court explained that rulings on the merits do not, by themselves, establish personal bias or hostility.
Because the motion was legally insufficient, the judge did not refer it to the Clerk for random assignment to another judge. The court also clarified that its earlier statement about sanctions had been a warning, not an imposed sanction. Although the court called the new motion frivolous and declined to impose sanctions at that time, it instructed Wright that filing another motion without an arguable legal or factual basis would lead to sanctions.
Disposition
The court denied Wright’s motion to disqualify the judge. It declined to sanction Wright at that time and warned that future baseless motions could result in sanctions.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.