Adams v. United States of America
- Ronnie Abrams
- 1:19-cv-04665
- U.S. District Court · Southern District of New York
- 2
In Adams v. United States, Judge Abrams denied Adams’s motion to disqualify the court, finding no basis to question judicial impartiality.
The order directly affected Seson Deon Teleo Adams’s request to disqualify the court and his ability to proceed without paying court fees for an appeal. The United States of America, the Internal Revenue Service, and Steven Mnuchin were named defendants in the underlying action.
What happened
In Adams v. United States of America, Seson Deon Teleo Adams, representing himself, asked the court to disqualify Judge Ronnie Abrams from his case. Adams had previously claimed that, as a “sovereign citizen,” he was not required to pay taxes, and the court had dismissed that case as factually and legally frivolous.
The court explained that disqualification requires a timely, sufficient showing of personal bias or circumstances that would cause a reasonable person to question the judge’s impartiality. Adams offered only his lack of confidence in the judiciary and did not identify a specific basis for disqualification. The court said that an unfavorable ruling, by itself, is not evidence of bias.
Judge Abrams denied Adams’s motion to disqualify the court. She also denied his ability to proceed without paying court fees for an appeal, certifying that an appeal from this order would not be taken in good faith, and directed the clerk to close the pending motion.
The detailed version
- Adams v. United States of America · No. 1:19-cv-04665
- Ronnie Abrams
- May 15, 2023
Background
Seson Deon Teleo Adams, proceeding without a lawyer, sued the United States of America, the Internal Revenue Service, and Steven Mnuchin in 2019. He alleged that identifying himself as a “sovereign citizen” meant he was not subject to legal obligations, including paying taxes. The court dismissed that case on May 29, 2019, calling it “both factually and legally frivolous.” More than three years later, Adams moved to disqualify the court under 28 U.S.C. §§ 144 and 455(a).
Legal standard
Section 144 permits recusal when a party files a timely and sufficient affidavit showing personal bias or prejudice against the party or in favor of an opposing party. Section 455(a) requires disqualification when a judge’s impartiality might reasonably be questioned. The court stated that the same substantive standard applies under both provisions: whether a reasonable person who knows all the facts would reasonably question the court’s impartiality.
Court’s analysis
The court found that Adams had not identified any basis for recusal. His only stated reason was that the plaintiffs had no confidence in the judiciary because of the direction of the case. The court explained that its earlier dismissal of Adams’s complaint was not evidence of bias and relied on the rule that judicial rulings almost never provide a valid basis for a bias or partiality motion. The court also repeated that the “sovereign citizen” theories underlying Adams’s claim were not established law.
Disposition
Judge Ronnie Abrams denied Adams’s motion to disqualify the court. Under 28 U.S.C. § 1915(a)(3), the court certified that any appeal from the order would not be taken in good faith and denied Adams’s ability to proceed without paying court fees for the purpose of an appeal. The clerk was directed to terminate the motion pending at Electronic Court Filing No. 6.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.