Erickson v. Commonwealth, 966 N.E.2d 795

Petitioner Heidi K. Erickson appeals from a single justice's denial of her petition under G. L. c. 211, § 3 challenging a probation violation proceeding in district court.
The district court found Erickson violated probation and imposed 30 days of home detention with modified probation terms.
Erickson sought a stay of the modified probation terms and other relief pending appeal, which the single justice denied.
Erickson also moved for recusal of the single justice, which was denied.
The court affirmed, stating extraordinary relief under c. 211, § 3 is reserved for exceptional cases when ordinary remedies are inadequate.
The court noted that appeals from probation-violation findings lie in the Appeals Court and found no bias or abuse in the single justice’s rulings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stay request was properly denied under c. 211, § 3	Erickson seeks stay pending appeal.	Relief denied as no extraordinary remedy warranted.	Denied; stay properly denied under § 3.
Whether the probation-violation challenge is appealable	Erickson may seek relief on probation-violation findings on appeal.	Appeal lies in the Appeals Court after final disposition of revocation or modification.	Appeal lies in the Appeals Court.
Whether the single justice abused discretion by denying recusal	Judge biased by extrajudicial sources; should recuse.	No bias shown; rulings reflect law, not extrajudicial influence.	No abuse; no extrajudicial bias shown.
Whether the extraordinary-relief denial was proper	Relief should be available pending appeal.	Extraordinary relief denied where ordinary remedies exist.	Properly denied; extraordinary relief not warranted.
Whether the court properly affirmed without additional relief	Any further relief requested should be considered.	Judgment affirmed; no additional relief needed.	Affirmed.

McGuinness v. Commonwealth, 420 Mass. 495 (Mass. 1995) (superintendence power reserved for extraordinary occasions)
Commonwealth v. Al Saud, 459 Mass. 221 (Mass. 2011) (probation violation challenges on appeal from final disposition)
Commonwealth v. Adkinson, 442 Mass. 410 (Mass. 2004) (recusal standard for bias or prejudice from extrajudicial sources)
Liteky v. United States, 510 U.S. 540 (U.S. 1994) (judicial opinions formed from earlier proceedings not inherently biased)
Demoulas v. Demoulas Super Mkts., Inc., 428 Mass. 543 (Mass. 1998) (context for evaluating recusal and bias claims)
Haddad v. Gonzalez, 410 Mass. 855 (Mass. 1991) (principles underlying impartial judicial decision-making)
Lena v. Commonwealth, 369 Mass. 571 (Mass. 1976) (standards for evaluating judicial impartiality)
Daye v. Commonwealth, 435 Mass. 463 (Mass. 2001) (bias standard; influence by prior proceedings not automatic disqualification)