Adetomiwa v. Redstone College, 1:15-cv-01413

Plaintiff Steven Adetomiwa sued Redstone College (Alta Colleges) and proceeded pro se.
Defendant moved to compel individual arbitration under the parties’ arbitration agreement and to stay/close litigation pending arbitration.
Magistrate Judge Nina Y. Wang recommended granting the motion to compel arbitration and denying plaintiff’s motions for appointment of counsel.
Plaintiff filed an objection alleging judicial bias and claiming the magistrate failed to consider his vision disability and financial inability to hire counsel.
The district court reviewed the magistrate judge’s Recommendation de novo, found no evidence of bias or error, and accepted the Recommendation.
The court granted the motion to compel arbitration, administratively closed the case pending arbitration, and required status notification after arbitration concludes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court should compel arbitration	Arbitration agreement should not be enforced (implicit challenge)	Parties agreed to individual arbitration; motion to compel arbitration should be granted	Granted: arbitration compelled; case administratively closed
Whether the magistrate judge was biased	Magistrate biased due to statements by defense counsel and alleged failure to consider plaintiff’s disability/finances	No evidence of bias; adverse ruling alone is not bias; magistrate properly considered issues	Denied: no appearance or evidence of bias; Recommendation accepted
Whether plaintiff is entitled to court‑appointed counsel	Plaintiff cited vision disability and inability to afford counsel	No entitlement shown; motions for appointment of counsel not supported	Denied: motions to appoint counsel denied
Standard of review for magistrate’s recommendation	(implied) Objections require specificity for de novo review	Motion to compel arbitration characterized as nondispositive; magistrate’s ruling reviewed under Rule 72(a) unless specific objection	Court treated motion to compel as nondispositive, reviewed Recommendation de novo despite lack of specific objections and found no error

Haines v. Kerner, 404 U.S. 519 (1972) (pro se pleadings construed liberally)
Hall v. Bellmon, 935 F.2d 1106 (10th Cir. 1991) (liberal construction of pro se filings)
PowerShare, Inc. v. Syntel, Inc., 597 F.3d 10 (1st Cir. 2010) (motion to compel arbitration is nondispositive)
Liteky v. United States, 510 U.S. 540 (1994) (adverse judicial rulings do not generally constitute bias)
United States v. One Parcel of Real Property Known As 2121 East 30th St., 73 F.3d 1057 (10th Cir. 1996) (objections to magistrate reports must be timely and specific)