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Celli v. New York City
1:24-cv-09743
S.D.N.Y.
Jun 3, 2025
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Background

  • Plaintiff Lucio Celli filed a motion seeking the recusal or disqualification of Judge John P. Cronan in ongoing federal civil litigation.
  • The request for recusal was based on alleged impartiality or appearance of bias by the presiding judge.
  • Plaintiff also sought a two-week extension to file objections to a recent Report and Recommendation and to respond to an Order to Show Cause regarding a possible filing injunction.
  • The Court reviewed the motion under the standards set by 28 U.S.C. § 455(a) and relevant Second Circuit case law.
  • The judge denied the recusal motion, finding no reasonable basis for doubting his impartiality.
  • The judge granted the plaintiff's procedural extension but warned against continued frivolous filings and possible sanctions.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Judicial recusal Judge's impartiality reasonably questioned No basis for recusal shown Denied: No reasonable basis for doubt
Extension of deadlines Needs more time to respond/prepare objections Contested or silent Granted: Extension until June 24
Filing injunction Not directly argued here Court notes abusive filings Warning: Further abuse may mean sanctions

Key Cases Cited

  • Liteky v. United States, 510 U.S. 540 (appearance of bias is enough to warrant recusal if a reasonable observer would doubt impartiality)
  • United States v. Yousef, 327 F.3d 56 (standard for judicial recusal is whether an objective observer would question impartiality)
  • In re Int’l Bus. Machs. Corp., 618 F.2d 923 (recusal should not be granted lightly due to wasted resources)
  • In re Drexel Burnham Lambert, Inc., 861 F.2d 1307 (judges have a duty not to recuse without valid grounds)
Read the full case

Case Details

Case Name: Celli v. New York City
Court Name: District Court, S.D. New York
Date Published: Jun 3, 2025
Docket Number: 1:24-cv-09743
Court Abbreviation: S.D.N.Y.