Candace Watson v. City of Jackson, 2014 Tenn. App. LEXIS 72

Watson sued the City of Jackson after slipping on a purportedly waxed floor while employed by the City; the trial court found Watson more than 50% at fault and entered judgment for the City.
Following trial, Watson proceeded pro se and submitted a pro se "Statement of Proceedings" to the Court of Appeals in lieu of a full transcript.
The City moved to strike Watson’s Statement under Tenn. R. App. P. 24, and the trial court granted the motion, finding the Statement not a fair, accurate, or complete account and containing unsworn internal commentary.
Watson then filed a post-judgment recusal motion alleging bias, prejudice, impropriety, and that the judge had personal knowledge/economic interest; she argued the court’s rejection of her Statement evidenced bias and collusion with the court reporter.
The trial judge denied recusal in a written order with specific factual findings, and Watson sought an accelerated interlocutory appeal under Tenn. Sup. Ct. R. 10B.
The Court of Appeals affirmed, holding Watson failed Rule 10B procedural requirements and failed to show a reasonable basis for questioning the judge’s impartiality; the court found no extrajudicial bias or extraordinary circumstances requiring recusal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial judge should be disqualified from preparing the appellate record (recusal under Tenn. Sup. Ct. R. 10, §2.11)	Watson: denial of her Statement of Proceedings and alleged omissions in the transcript evidence judicial bias, discrimination, and collusion with the court reporter	City: no factual basis for recusal; judge properly applied Rule 24 and approved a verbatim transcript; Watson's allegations are unsupported	Denied — no objective basis for questioning impartiality; adverse rulings and disputed transcript content do not establish extrajudicial bias
Whether Watson complied with Rule 10B procedural requirements for recusal appeal	Watson: urges recusal despite procedural defects	City: argues motion lacks required statements and supporting materials; trial court found procedural deficiencies	Court noted Watson failed to affirm motion wasn’t for harassment and failed to include required orders, but reviewed merits anyway; procedural noncompliance affirmed as a fault

Bean v. Bailey, 280 S.W.3d 798 (Tenn. 2009) (right to a fair trial before an impartial tribunal is fundamental)
Davis v. Liberty Mut. Ins. Co., 38 S.W.3d 560 (Tenn. 2001) (objective test for recusal: whether a reasonable person would question judge's impartiality)
State v. Austin, 87 S.W.3d 447 (Tenn. 2002) (purpose of recusal rules to avoid prejudgment and preserve public confidence)
Alley v. State, 882 S.W.2d 810 (Tenn. Crim. App. 1994) (prejudice must stem from an extrajudicial source to warrant recusal)
Kinard v. Kinard, 986 S.W.2d 220 (Tenn. Ct. App. 1998) (appearance of impartiality is as important as actual impartiality)
Duke v. Duke, 398 S.W.3d 665 (Tenn. Ct. App. 2012) (adverse rulings, even if numerous, do not alone justify disqualification)