Grogan v. New York University
- Laura Swain
- 1:20-cv-03345
- U.S. District Court · Southern District of New York
- 8
In Grogan v. New York University, Judge Wang denied Jared J. Grogan’s recusal motion because alumni ties and prior rulings did not show bias.
Jared J. Grogan, New York University, NYU in Abu Dhabi Corporation, and Magistrate Judge Ona T. Wang; the court denied Grogan’s request for recusal.
What happened
In Grogan v. New York University, Jared J. Grogan, representing himself, asked Magistrate Judge Ona T. Wang to step aside from the case. He pointed to Judge Wang’s alumni connection to New York University, a 2016 award from its law school, and rulings he believed favored the defendants. The case also includes employment-related claims under the Americans with Disabilities Act and a contract claim, but this order addressed only recusal.
The court explained that unfavorable rulings alone generally do not establish that a judge is biased. It also concluded that being an alumna of the university was not enough to create a reasonable question about impartiality or show a qualifying interest in a party. The court treated Grogan’s filing as a request under the federal judicial-disqualification statute.
Judge Wang denied Grogan’s motion for recusal. The order did not decide the underlying employment or contract claims.
The detailed version
- Grogan v. New York University · No. 1:20-cv-03345
- Laura Swain
- Oct. 12, 2023
Background
Jared J. Grogan originally filed the case while representing himself. After obtaining counsel, he filed an amended complaint asserting three employment-related claims: discrimination under the Americans with Disabilities Act, retaliation under that statute, and breach of contract. Settlement efforts later failed, and Grogan proceeded without counsel.
On September 13, 2023, Grogan filed a letter raising several issues, including a request that Magistrate Judge Ona T. Wang recuse herself. He relied on Judge Wang’s status as an alumna of New York University’s law school, her receipt of the school’s 2016 Public Service Award, her alleged failure to disclose those facts, and prior reports and recommendations in the case that he viewed as favoring the defendants. The court treated the relevant portions of his filing as a motion for recusal under Sections 455(a) and 455(b) of Title 28 of the United States Code. Those provisions address circumstances in which a judge’s impartiality might reasonably be questioned or specific forms of bias, prejudice, or financial interest exist.
Analysis
The court first held that prior unfavorable rulings, without more, do not provide a reasonable basis to question a judge’s impartiality. It reviewed the procedural history and noted that Grogan had received every extension he requested, including extensions based on his stated need for additional time. The court concluded that the record did not support his claim of favoritism.
The court also held that an alumni affiliation, by itself, is insufficient to establish bias, prejudice, or a disqualifying interest in a party or the subject of the dispute. Judge Wang explained that treating an educational affiliation as a basis for recusal would lead to unreasonable results whenever a party, lawyer, or witness had attended an institution connected to a judge.
Ruling
Judge Wang denied Grogan’s motion for recusal. The order did not resolve Grogan’s underlying Americans with Disabilities Act or breach-of-contract claims. The court also directed the Clerk of Court to mail a copy of the order to Grogan, who was representing himself.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.