Nedra B. Drayton v. Cooper Moving Services, W2017-00718-COA-T10B-CV

Pro se plaintiff Nedra B. Drayton sued Cooper Moving Services and moved to recuse the Chancery Court Chancellor, alleging a pattern of bias and appearance of impropriety affecting impartiality.
Drayton claimed specific incidents: denial of chances to present evidence, the Chancellor requiring opposing counsel’s consent for hearing dates, threatening dismissal, urging her to hire an attorney, alleged failure to address opposing counsel’s misconduct, and an improper ex parte solicitation of counsel.
The Chancellor denied the recusal motion, initially issuing a March 27 order that failed to state written grounds, then issuing an amended March 30 order finding Drayton had fabricated grounds and suggesting her filings were for delay or harassment.
Drayton filed an interlocutory appeal as of right under Tenn. Sup. Ct. R. 10B challenging whether the denial violated Rule 10B §1.03 by giving reasons inconsistent with her stated grounds.
The Appellate Court reviewed only the record Drayton provided (no hearing transcripts) and concluded the record was insufficient to overturn the Chancellor’s factual findings or show reversible error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court violated Tenn. Sup. Ct. R. 10B §1.03 by denying recusal for reasons inconsistent with Drayton’s stated grounds	Chancellor denied recusal for fabricated grounds; denial inconsistent with factual/legal grounds supporting recusal	Chancellor properly exercised discretion; Drayton’s allegations are unsupported and stem from dissatisfaction with rulings	Affirmed: record inadequate to show error; Chancellor’s factual findings entitled to deference and recusal not required

Bean v. Bailey, 280 S.W.3d 798 (Tenn. 2009) (right to fair trial before an impartial tribunal and appearance-of-impartiality standard)
State v. Austin, 87 S.W.3d 447 (Tenn. 2002) (appearance of prejudice undermines confidence in judiciary)
Kinard v. Kinard, 986 S.W.2d 220 (Tenn. Ct. App. 1998) (judge must be impartial in fact and appearance)
Offutt v. United States, 348 U.S. 11 (U.S. 1954) (justice must satisfy appearance of justice)
Smith v. State, 357 S.W.3d 322 (Tenn. 2011) (recusal required when impartiality might reasonably be questioned)
Alley v. State, 882 S.W.2d 810 (Tenn. Crim. App. 1994) (distinguishes extrajudicial bias from adverse rulings; not all bias warrants recusal)
State v. Cannon, 254 S.W.3d 287 (Tenn. 2008) (adverse rulings ordinarily do not establish bias)
State v. Reid, 313 S.W.3d 792 (Tenn. 2006) (erroneous or numerous rulings do not alone require disqualification)
Fields v. State, 40 S.W.3d 450 (Tenn. 2001) (trial court findings of fact presumed correct on appeal)