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Liteky v. United States

Facts

In the 1991 trial at issue, petitioners were charged with willful destruction of property of the United States in violation of 18 U.S.C. 1361. Before trial, petitioners moved to disqualify the District Judge pursuant to 28 U.S.C. 455(a), relying on events from an earlier trial involving one of the petitioners. The District Judge denied the motion, stating that matters arising from judicial proceedings were not a proper basis for recusal. Petitioners were ultimately convicted.

In the 1991 trial at issue here, petitioners were charged with willful destruction of property of the United States in violation of 18 U.S.C. 1361. Before trial petitioners moved to disqualify the District Judge pursuant to 28 U.S.C. 455(a). The motion relied on events that had occurred during and immediately after an earlier trial, involving petitioner Bourgeois, before the same District Judge.

Issue

Whether required recusal under 28 U.S.C. 455(a) is subject to the limitation known as the 'extrajudicial source' doctrine.

Whether required recusal under 28 U.S.C. 455(a) is subject to the limitation that has come to be known as the 'extrajudicial source' doctrine.

Rule

Section 455(a) of Title 28 of the United States Code requires a federal judge to disqualify himself in any proceeding in which his impartiality might reasonably be questioned.

Section 455(a) of Title 28 of the United States Code requires a federal judge to 'disqualify himself in any proceeding in which his impartiality might reasonably be questioned.'

Analysis

The court held that the presence of an extrajudicial source does not establish bias, and the absence of such a source does not preclude bias. The opinions formed by a judge based on facts introduced or events occurring in the course of the current or prior proceedings do not amount to bias unless they display deep-seated favoritism or antagonism that would make fair judgment impossible.

The court held that the presence of an extrajudicial source did not establish bias, and the absence of an extrajudicial source did not preclude bias. The opinions formed by a judge on the basis of facts introduced or events occurring in the course of the current proceedings, or of prior proceedings, did not amount to bias or partiality unless they displayed a deep-seated favoritism or antagonism that would make fair judgment impossible.

Conclusion

The Supreme Court affirmed the judgment denying petitioners' motion for recusal, concluding that the judge's conduct did not warrant disqualification under 455(a).

The judgment denying petitioners' motion for recusal was affirmed.

Who won?

The United States prevailed in the case because the Supreme Court upheld the lower court's ruling that the judge's actions did not constitute grounds for recusal.

The United States prevailed in the case because the Supreme Court upheld the lower court's ruling that the judge's actions did not constitute grounds for recusal.

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