Ligeri v. Amazon.com Services LLC
2:25-cv-00796
| W.D. Wash. | Jul 15, 2025Background
- Plaintiff Benjamin Joseph Ligeri filed motions to vacate reassignment of his cases against Amazon.com Inc., citing alleged procedural errors.
- Ligeri asserted that Judge John H. Chun should recuse himself due to a perceived risk of partiality arising from Judge Chun's reported affiliation with the American Arbitration Association.
- Plaintiff relied on 28 U.S.C. § 455(a), which requires judges to recuse themselves if their impartiality might reasonably be questioned.
- Plaintiff did not provide any affidavit or specific factual support for the claim of partiality, relying largely on allegations about Judge Chun’s background.
- The court construed Ligeri’s motion as a motion for recusal and addressed only the recusal issue in this order.
- Judge Chun denied the motion and directed the clerk to refer the motion to the chief judge for further review, as per local rules.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Judicial Recusal | Judge Chun’s affiliation with AAA creates appearance of bias | No specific argument noted; implied opposition to recusal | Motion denied; no evidence of reasonable impartiality concern |
Key Cases Cited
- Taylor v. Regents of Univ. of Cal., 993 F.2d 710 (9th Cir. 1993) (clarifies requirement of an “extrajudicial source” of bias for recusal)
- United States v. Sibla, 624 F.2d 864 (9th Cir. 1980) (recusal motions must be supported by specific factual allegations, not conclusory statements)
- In re Complaint of Jud. Misconduct, 584 F.3d 1230 (9th Cir. 2009) (vague claims do not meet the evidentiary threshold for judicial misconduct or recusal)