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Civil Rights: Other | Connecticut
Order on Motion for Order
ORDER denying Motion to Disqualify 45 . The Washingtons have filed a Motion to Disqualify 45 which asks this court to recuse itself, along with an Affidavit of Bias and Prejudice 46 and a supporting memorandum 47 .Under 28 U.S.C. § 455, a judge shall recuse herself "in any proceeding in which [her] impartiality might reasonably be questioned." 28 U.S.C. § 455(a). Section 455(b) also includes specific grounds for recusal, including "[w]here [s]he has a personal bias or prejudice concerning a party, or personal knowledge of disputed evidentiary facts concerning the proceeding." Id. § 455(b). The Washingtons argue that the court's impartiality should be questioned "given the pattern of adverse rulings" and "bias against pro se litigants generally and" the Washingtons specifically. ECF No. 47 at 6. The Washingtons also repeat the arguments already raised and rejected in their Motion to Vacate or Set Aside Order. See ECF Nos. 39 , 43 . These arguments include that the court failed to "liberally construe pro se pleadings," "fraudulent misrepresentation" of the Washington's 29-page Complaint, 107-page Affidavit, and 461 pages of exhibits as a "600-page complaint," and the "constructive conversion" of their pleadings. ECF No. 45 , at 5-6.These complaints about prior judicial rulings in this case are not evidence of personal bias or prejudice or personal knowledge of disputed evidentiary facts concerning the proceeding. Instead, the Washingtons explicitly argue that a "pattern of adverse rulings" is the basis for their request. ECF No. 45 , at 5. Similarly, the Washingtons' only evidence of bias against pro se litigants are the rulings of this court against the Washingtons. Id. at 6; ECF No. 47 , at 6. The Supreme Court has held that "judicial rulings alone almost never constitute a valid basis for a bias or partiality motion." Liteky v. U.S., 510 U.S. 540 (1994). The Washingtons have presented "judicial rulings alone" to support their motion and pointed to no exceptions to the Supreme Court's holding in Liteky. I therefore deny the Motion to Disqualify 45 . Signed by Judge Sarah F. Russell on 7/14/2026. (dl)
Dismiss
MOTION to Dismiss by Dennis McManus, Shannon Miles, Jay Moran, La'Mont Stevenson, Town of Manchester.Responses due by 7/30/2026 (Attachments: # 1 Memorandum in Support)(Glass, Andrew)
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