Manchanda v. Lane
- Naomi Buchwald
- 1:23-cv-07637
- U.S. District Court · Southern District of New York
- 2
In Manchanda v. Lane, Judge Buchwald denied plaintiffs’ request for recusal based on dissatisfaction with one case-management order.
The ruling affected the plaintiffs’ request to have the court recuse itself; the court denied that request.
What happened
In Manchanda v. Lane, the plaintiffs asked the court to remove Judge Naomi Reice Buchwald from the case. The case had been randomly assigned to her, and the request was based on a case-management order she had issued.
The court explained that a judge may be disqualified when impartiality might reasonably be questioned, but a strong presumption of impartiality applies. A party’s dislike of a judge or disagreement with the judge’s rulings is not enough.
Judge Buchwald ruled that the plaintiffs’ suggestion, based on a single case-management order, did not overcome that presumption. The court denied the request for recusal.
The detailed version
- Manchanda v. Lane · No. 1:23-cv-07637
- Naomi Buchwald
- Oct. 12, 2023
Background
The court received a letter dated October 6, 2023, requesting that it recuse itself—that is, remove itself from the case. The court stated that, like all new cases in the Southern District of New York, this case had been randomly assigned. It explained that a party cannot seek reassignment merely because of a preference for, dislike of, or disappointment with a particular judge’s rulings.
Legal standard
Under 28 U.S.C. § 455(a), a judge may recuse herself when her impartiality might reasonably be questioned. The court also stated that judges are presumed to be impartial, and that adequate proof is required to overcome that presumption. It cited authority holding that dissatisfaction with case-management decisions is not a basis for recusal.
Ruling
The court held that the plaintiff’s suggestion that the court should be disqualified because of a single case-management order was insufficient to overcome the strong presumption of impartiality. Judge Naomi Reice Buchwald therefore denied the request for recusal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.