Hazari v. County of Santa Clara
5:19-cv-04392
N.D. Cal.Apr 14, 2025Background
- Plaintiff Cyrus Hazari filed a motion to disqualify the presiding judge in his long-running civil case against the County of Santa Clara and others in the Northern District of California.
- The motion was prompted by the court’s denial of Hazari's requests for disability accommodations and for further stays in the proceedings.
- Hazari argued that the judge should be disqualified due to alleged bias, partiality, and improper handling of disability-related issues.
- The plaintiff's filings were lengthy and prolix, but the court noted his ability to prepare and submit extensive documents, casting doubt on claims of incapacity.
- The court reviewed the sufficiency of Hazari's disqualification motion under both 28 U.S.C. § 144 and 28 U.S.C. § 455.
- No hearing was held on the motion and the defendants were not required to respond.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Disqualification for bias and partiality | Judge cannot preside over cases involving disabled litigants without independent review | Not needed; the judge is impartial | Motion denied; no evidence of bias or prejudice |
| Denial of stay due to disability | Plaintiff's illness entitles him to accommodation and stay of proceedings | Plaintiff capable of prosecuting the case | No stay warranted; filings show capability |
| Sufficiency of disqualification affidavit | Affidavit and arguments show personal bias and improper rulings by the judge | Judge presumed impartial; no sufficient showing by Hazari | Affidavit insufficient under §§ 144 and 455 |
| Excessive filings and rule compliance | Not addressed directly; motions exceeded local page limits | Not directly addressed | Non-compliance warned; future violations may be stricken |
Key Cases Cited
- United States v. Azhocar, 581 F.2d 735 (9th Cir. 1978) (court must determine legal sufficiency of disqualification affidavit)
- United States v. Montecalvo, 545 F.2d 684 (9th Cir. 1976) (judge subject to disqualification affidavit does not assess its truthfulness)
- Liteky v. United States, 510 U.S. 540 (1994) (judicial rulings almost never form a valid basis for recusal)
- United States v. Holland, 519 F.3d 909 (9th Cir. 2008) (standard for disqualification is whether reasonable person questions impartiality)
- Clemens v. U.S. Dist. Ct., 428 F.3d 1175 (9th Cir. 2005) (section 455(a) claims fact-driven, guided by circumstances)