Foregger v. Redfin Corporation, 4:24-cv-05701

Christina Foregger, representing herself, filed four motions to disqualify Judge Haywood Gilliam from her federal civil case against Redfin Corporation in the Northern District of California.
None of Foregger's motions specified a federal statutory or rule-based reason for disqualification, though the court reviewed them generously due to her pro se status.
The court evaluated the motions under 28 U.S.C. §§ 455, 144, and Canon 3(C) of the Code of Conduct for United States Judges, which govern judicial recusal for bias, prejudice, or reasonable appearance of impartiality.
Foregger’s motions centered on Judge Gilliam allegedly failing to take action against attorney Taylor Neff for practicing law in California without a license and allegedly covering up for unethical attorneys.
The claims were found to be frivolous, with no facts suggesting reasonable grounds for questioning the judge's impartiality.
The court warned Foregger against further frivolous filings, citing potential sanctions and loss of electronic filing privileges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Judicial Disqualification	Judge should be disqualified for bias (failure to report attorney misconduct)	Not specified	Denied—no legal or factual basis for recusal
Sufficiency of Affidavit	N/A (no sufficient affidavit filed)	Not specified	Denied—no timely or sufficient affidavit filed
Standard for Disqualification	Judge’s conduct reflects bias or partiality	Not specified	No reasonable question of impartiality found
Frivolous Filings	Persistent motions for recusal are justified	Not specified	Warned of sanctions for further frivolous filings

United States v. Holland, 519 F.3d 909 (9th Cir. 2008) (articulates standard for disqualification based on impartiality)
United States v. Sibla, 624 F.2d 864 (9th Cir. 1980) (affidavit requirements and standards for motions under 28 U.S.C. § 144)