In re Disqualification of Celebrezze, 135 Ohio St. 3d 1218

Affidavits seeking disqualification were filed by Mary E. Papcke (on behalf of defendant) and Nicole Misconin.
The affidavits targeted Judge Leslie Ann Celebrezze and Magistrate Patrick R. Kelly regarding alleged bias or appearance of impropriety.
Judge Celebrezze acknowledged prior recusal from cases involving Papcke’s party, citing a personal conflict.
She argues the prior circumstances no longer exist and that disqualification is not the proper vehicle to resolve concerns about Magistrate Kelly.
Affiants argued the case involved appearance of impropriety and bias, and noted disciplinary grievances against the magistrate.
The Supreme Court denied disqualification, allowing the case to proceed before Judge Celebrezze.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether former recusal requires disqualification now	Papcke argues appearance of impropriety remains.	Celebrezze asserts recusal circumstances no longer exist.	No disqualification based on attenuated link.
Whether appearance of impropriety exists given the attenuated relationship	Affidavits show potential bias due to past conflict.	No reasonable observer would doubt impartiality; past relations are stale.	No appearance of impropriety justifying disqualification.
Whether affidavits establish bias warranting disqualification	Affidavits show party conflict with judge.	Vague/unsubstantiated allegations are insufficient.	Affidavits do not establish bias or prejudice.
Whether bias against Magistrate Kelly can be considered	Misconin and Papcke seek Kelly disqualification.	R.C. 2701.03 does not permit review of bias against magistrates.	Request against Magistrate Kelly denied.
Whether filing a disciplinary grievance automatically triggers disqualification	Grievance against judge could compel disqualification.	Disciplinary complaints do not automatically disqualify a judge.	Not automatic; not a basis for disqualification here.

In re Disqualification of Lucci, 117 Ohio St.3d 1242 (2012-Ohio-7230) (appearance-of-impropriety standard for judges)
In re Disqualification of Shuff, 117 Ohio St.3d 1230 (2004-Ohio-7355) (appearance concerns with judge)
In re Disqualification of Walker, 36 Ohio St.3d 606 (1988-Ohio-522) (voluntary recusal insufficient for unrelated case)
In re Disqualification of Martin, 74 Ohio St.3d 1221 (1990-Ohio-1380) (voluntary recusal does not imply broad disqualification)
In re Disqualification of George, 100 Ohio St.3d 1241 (2003-Ohio-5489) (presumed bias not overcome without compelling appearance)
In re Disqualification of Kilpatrick, 47 Ohio St.3d 605 (1989-Ohio-202) (not automatic disqualification due to grievance)
In re Disqualification of Wilson, 77 Ohio St.3d 1250 (1996-Ohio-1257) (authority on review of magistrate bias claims)
In re Disqualification Evans, 127 Ohio St.3d 1213 (2009-Ohio-7204) (bias against magistrate not reviewable under 2701.03)
In re Disqualification of Celebrezze, 135 Ohio St.3d 1218 (2012-Ohio-6304) (affidavits denied; case proceeding before Celebrezze)