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S.D.N.Y.Procedural orderFiled Mar. 13, 2024

Adams v. United States of America

Judge
Ronnie Abrams
Docket
1:19-cv-04665
Court
U.S. District Court · Southern District of New York
Pages
2
Civil ProcedurePro Se
In one sentence

In Adams v. United States, Judge Abrams denied Adams’s motion to disqualify the court because it repeated an earlier denied motion.

Who this affects

Seson Deon Teleo Adams’s request to disqualify the court was denied; the United States of America, the Internal Revenue Service, and Steven Mnuchin were the named defendants.

What happened

In Adams v. United States of America, Seson Deon Teleo Adams, who was representing himself, asked the court to disqualify itself from his case. He had previously made the same request, and the court had denied it.

The court said the new motion was identical to Adams’s earlier motion. The court therefore denied the motion for the same reasons given in its May 16, 2023 order.

Judge Ronnie Abrams denied the motion and directed the Clerk of Court to terminate the pending motion. The order did not restate the reasons from the earlier order.

The detailed version

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

Case
Adams v. United States of America · No. 1:19-cv-04665
Judge
Ronnie Abrams
Date
Mar. 13, 2024

Background

Seson Deon Teleo Adams filed this action in 2019 against the United States of America, the Internal Revenue Service, and Steven Mnuchin. Adams represented himself. He alleged that, because he is a “sovereign citizen,” he was not subject to legal obligations, including paying taxes. The court dismissed the case on May 29, 2019, describing it as “both factually and legally frivolous.”

Earlier and Current Motions

On January 19, 2023, Adams moved to disqualify the court under 28 U.S.C. §§ 144 and 455(a), which address when a judge may be disqualified. The court denied that motion on May 16, 2023. Adams filed another motion to disqualify the court on March 8, 2024. The opinion states that the substance of the two motions was identical.

Ruling

The court denied Adams’s motion to disqualify the court for the same reasons stated in its May 16, 2023 memorandum order and opinion. The Clerk of Court was directed to terminate the motion listed at ECF No. 12. The March 13, 2024 order did not repeat the earlier order’s reasoning.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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