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Frank Ragozzine v. Youngstown State University
783 F.3d 1077
6th Cir.
2015
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Background

  • Frank Ragozzine, a tenure-track professor in YSU's Psychology Department, was denied tenure for lack of promise of consistent scholarly production.
  • Ragozzine alleged Title VII discrimination based on sex, Equal Protection, and violations of the Family Medical Leave Act, plus due process claims, and the district court granted summary judgment for YSU on all claims.
  • After summary judgment, Ragozzine sought disqualification of the district judge due to a dating relationship with a YSU professor.
  • The district court denied recusal, concluding no reasonable person would question the judge's impartiality.
  • On appeal, the Sixth Circuit affirmed the district court's summary judgment ruling and the denial of recusal, reinforcing the recusal standard under 28 U.S.C. § 455(a).
  • The court discussed the relationship between the statutory recusal standard and Canon 3C of the Code of Conduct, and the role of advisory opinions in interpretation.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether summary judgment on all claims was proper. Ragozzine contends discrimination and due process claims survive. YSU argues evidence fails to show motive or impairment of rights. Summary judgment affirmed; no merit to claims.
Whether the district court properly denied recusal. Appearance of impropriety due to dating relationship warrants recusal. Impartiality not reasonably questioned; no disqualifying conflict. Recusal not required; district court's denial affirmed.

Key Cases Cited

  • Hughes v. United States, 899 F.2d 1495 (6th Cir. 1990) (interprets § 455(a) impartiality standard)
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Case Details

Case Name: Frank Ragozzine v. Youngstown State University
Court Name: Court of Appeals for the Sixth Circuit
Date Published: Apr 22, 2015
Citation: 783 F.3d 1077
Docket Number: 14-3365
Court Abbreviation: 6th Cir.