Court, Explained
U.S. Federal District Courts
←Back to docket
S.D.N.Y.Procedural orderFiled Sept. 16, 2020

Chevron Corporation v. Donziger

Judge
Lewis Kaplan
Docket
1:11-cv-00691
Court
U.S. District Court · Southern District of New York
Pages
5
Civil ProcedureCriminal
In one sentence

In United States v. Steven Donziger, Judge Preska denied Donziger’s recusal request and moved trial from November 3 to November 4.

Who this affects

Steven Donziger’s request to remove Judge Preska’s court from the case was denied, and the start of his trial was moved from November 3 to November 4.

What happened

In United States v. Steven Donziger, Steven Donziger asked the court to remove itself from his case, repeating earlier claims about Judge Kaplan’s role and adding complaints about the court’s rulings and treatment of him.

The court rejected those arguments, finding that Donziger had identified no overlooked law or facts and that disagreement with the court’s decisions did not show bias. The court denied the motion to disqualify.

Judge Preska also said that setting the trial for election day resulted from an oversight and adjourned the trial’s start to November 4.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Chevron Corporation v. Donziger · No. 1:11-cv-00691
Judge
Lewis Kaplan
Date
Sept. 16, 2020

Background

Steven Donziger filed a second request for the court to remove itself from his case. His earlier request had challenged Judge Kaplan’s direct assignment of the case to Judge Preska and alleged that Judge Kaplan was improperly involved or communicating with the court. The court had denied that earlier request on May 7, 2020.

In the renewed request, Donziger repeated those arguments and claimed that the court had treated him unfairly and favored the Government. He pointed to the court’s description of parts of his litigation strategy, conditions imposed on his release before trial, and the setting of trial for November 3, which was election day.

Analysis

The court treated Donziger’s renewed arguments about Judge Kaplan as a motion asking the court to reconsider its earlier decision. It explained that reconsideration requires the moving party to identify controlling decisions or information the court overlooked that could reasonably change the result. The court found that Donziger had identified no such law or facts and had instead repeated earlier speculation.

The court also rejected Donziger’s claims based on the court’s rulings and treatment of him. It stated that a party’s unhappiness with decisions against that party is not a basis for removing a judge. The court concluded that, considering all the facts, a reasonable person would not question its impartiality.

Disposition

The court denied Donziger’s motion to disqualify the court. It also stated that the November 3 trial date had resulted from a simple calculation error and ordered that the trial instead begin on Wednesday, November 4.

Judge

The order was signed by Loretta A. Preska, United States District Judge.

The authoritative version

Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
Summary written with AI assistance. See how summaries are made. Spot something wrong? Tell us.