Anderson Lumber Company, Inc. v. Chris Kinney, E2016-01640-COA-R3-CV

Anderson Lumber sued Kinney Custom Interiors (Chris and Margaret Kinney) for unpaid business debts; William Kinney later moved to intervene claiming partnership and was added as a defendant.
Multiple pretrial motions, discovery disputes, and hearings occurred between 2013–2015; a Special Master was appointed and issued a report assessing amounts owed.
Case was removed to federal court and later remanded; Plaintiff voluntarily nonsuited claims against Chris Kinney (who was deceased).
In May 2016 William and Margaret Kinney filed a Motion for Disqualification/Recusal of the trial judge alleging bias based on prior rulings and the judge’s social, civic, and campaign connections with Plaintiff’s principals, counsel, and the Special Master.
The trial judge issued a detailed 28‑page order denying recusal, explaining factual responses and concluding relationships and past contributions were de minimis and did not create a reasonable appearance of bias.
Defendants appealed under Tenn. Sup. Ct. R. 10B; the Court of Appeals affirmed the denial and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether judge must recuse for alleged bias arising from prior adverse rulings	Judge’s rulings were proper and do not show bias	Adverse and repeated rulings demonstrate bias	Denied; adverse rulings alone insufficient to require recusal
Whether civic/social ties to plaintiff, counsel, or donors require recusal	Civic ties are minimal and routine; no extrajudicial contacts about the case	Shared church, boards, and community ties create appearance of partiality	Denied; mere acquaintance or civic service does not mandate recusal
Whether past campaign contributions by attorneys/affiliates require recusal	Contributions were minimal, made long before, and not by litigants in current campaign	Contributions create reasonable appearance of bias	Denied; past/minimal campaign contributions alone do not require recusal
Whether judge’s past association with plaintiff’s firm, involvement with Special Master, or alleged extrajudicial communications require recusal	Past professional ties are historical and no extrajudicial case discussions occurred	Prior firm employment and alleged interactions with counsel/Special Master show partiality	Denied; no evidence of extrajudicial influence or personal bias shown

Bean v. Bailey, 280 S.W.3d 798 (Tenn. 2009) (right to impartial tribunal; appearance of bias matters)
State v. Austin, 87 S.W.3d 447 (Tenn. 2002) (preservation of public confidence in judicial neutrality)
Kinard v. Kinard, 986 S.W.2d 220 (Tenn. Ct. App. 1998) (appearance of impartiality requirement)
Offutt v. United States, 348 U.S. 11 (U.S. 1954) (justice must satisfy appearance of justice)
Smith v. State, 357 S.W.3d 322 (Tenn. 2011) (recusal required when impartiality might reasonably be questioned)
Alley v. State, 882 S.W.2d 810 (Tenn. Crim. App. 1994) (bias must be extrajudicial and personal to merit disqualification)
State v. Cannon, 254 S.W.3d 287 (Tenn. 2008) (adverse rulings do not ordinarily establish bias)
State v. Reid, 313 S.W.3d 792 (Tenn. 2010) (erroneous or numerous rulings, without more, do not justify recusal)