Williams v. NYC Board of Elections
- Katharine Parker
- 1:23-cv-05460
- U.S. District Court · Southern District of New York
- 5
Williams v. NYC Board of Elections: Judge Parker granted a correction request but denied Williams’s motion for recusal.
Carman Williams’s law-degree statement was corrected, but her request to have Judge Parker recused was denied; the order also addressed Judge Parker’s continuing role in managing pretrial discovery.
What happened
In Williams v. NYC Board of Elections, Carman Williams asked the court to correct an earlier statement that she did not have a law degree and asked Judge Katharine H. Parker to step aside from the case. The case involves Williams’s claims about losing her position as a poll worker.
The court acknowledged Williams’s representation that she has a law degree and passed the New York State Bar Exam. It explained that its earlier discussion of special treatment sometimes given to people without lawyers no longer applied based on that representation.
Judge Parker denied the recusal motion because Williams identified no bias from outside the case, and the judge said she had no such bias or prejudice. The court also rejected Williams’s concerns about the case-management conference, hearsay statements, filings, and a defendant’s participation. The correction request was granted, and the recusal motion was denied.
The detailed version
- Williams v. NYC Board of Elections · No. 1:23-cv-05460
- Katharine Parker
- Mar. 26, 2024
Background
Carman Williams sued the New York City Board of Elections and individual defendants over alleged retaliation and libel connected to the termination of her position as a poll worker. This order addressed two requests by Williams: correction of an earlier statement that she did not have a law degree, and recusal, meaning that Judge Parker should withdraw from the case under 28 U.S.C. § 455.
Correction Request
The court previously denied Williams’s request for free volunteer legal representation and stated that she did not have a law degree. Williams then told the court that she has a JD degree and passed the New York State Bar Exam. The court granted the request for a correction and acknowledged, based on Williams’s representation, that she has a law degree.
The court further stated that its earlier discussion of the special consideration sometimes given to people representing themselves without lawyers no longer applied in light of Williams’s representation that she has a law degree and passed the New York bar exam.
Recusal Motion
The court explained that recusal may be required when a judge has personal bias or prejudice or when impartiality could reasonably be questioned. It found that Williams had not presented an allegation or evidence of bias arising from an outside source. The court also affirmatively stated that it had no such bias or prejudice.
The court rejected Williams’s claims that Judge Parker acted hostilely at an initial case-management conference. It explained that the conference involved setting a discovery schedule, which required questions about the claims and defenses, and that both Williams and defense counsel had time to be heard. The court also said that Williams was not prejudiced when defense counsel read statements allegedly constituting hearsay because the conference was not a trial or evidentiary hearing.
The court addressed Williams’s concern that Reshma Patel attended the conference despite allegedly being in default. It stated that Williams had not requested a default judgment against Patel, none had been issued, and Patel had participated in the case without a lawyer since January 8, 2024. The court also said that filings had been mailed to Williams’s address on the docket and reminded her that she was responsible for staying informed about filings.
Disposition
Judge Katharine H. Parker granted Williams’s request for a correction and denied Williams’s motion for recusal. The order states that Judge Parker’s role is limited to managing general pretrial discovery and that she would not preside over a trial or decide dispositive motions. The order did not decide the merits of Williams’s retaliation or libel claims.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.