Pazuniak Law Office, LLC v. Pi-Net International, Inc., N14C-12-259 EMD

Plaintiffs Pazuniak Law Office, LLC and George Pazuniak sued Pi-Net International, Inc. and Dr. Lakshmi Arunachalam seeking declaratory relief and alleging libel and tortious interference; Arunachalam answered and asserted counterclaims and third‑party claims.
Dr. Arunachalam filed an application for certification for interlocutory appeal and a motion seeking recusal of Judge Eric M. Davis, alleging the judge hindered her access to justice, intimidated her, threatened her, and committed "honest judicial services fraud."
This was Arunachalam’s second motion to recuse Judge Davis; the court previously denied an earlier recusal motion in a December 11, 2015 opinion.
The court reviewed the filings, concluded no hearing was necessary, and considered Delaware recusal standards (including the Los v. Los test and the Delaware Judges’ Code of Judicial Conduct).
The court found no subjective bias by the judge and no objective appearance of bias a reasonable observer would find concerning; it characterized the judge’s prior actions (striking pleadings, imposing a $100 sanction for an unfounded bias accusation, and ordering compliance with rules) as measured and rule‑based rather than biased.
The court denied the motion to recuse; the request for recusal within Arunachalam’s interlocutory‑appeal application was therefore denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Judge Davis must recuse for alleged bias and hindering access to justice	Pazuniak Law: No recusal; judge’s conduct was reasonable and rule‑based	Arunachalam: Judge’s actions created appearance of impropriety and hindered access to justice, warranting recusal	Denied — judge had no subjective bias and no objective appearance of bias under Los v. Los test
Whether the judge’s prior rulings and sanctions support an appearance of partiality	Pazuniak Law: Sanctions and strikes were appropriate enforcement of rules, not bias	Arunachalam: Sanctions and striking pleadings demonstrate intimidation and prejudice	Denied — court held actions were measured responses to procedural violations, not evidence of bias
Whether interlocutory certification should proceed insofar as it seeks recusal	Pazuniak Law: Certification as to recusal is unsupported	Arunachalam: Sought certification as part of appeal of alleged denial of access to justice and recusal denial	Denied as to recusal — interlocutory appeal application does not change recusal result
Whether vague allegations (e.g., honest‑services fraud, external affiliations) require recusal	Pazuniak Law: Allegations are unsupported and irrelevant	Arunachalam: Raised various external matters to suggest bias	Denied — court found allegations unsupported and referenced prior recusal opinion and record rebutting them

Jones v. State, 940 A.2d 1 (Del. 2007) (judicial impartiality principles)
Home Paramount Pest Control v. Gibbs, 953 A.2d 219 (Del. 2008) (recusal standard: reasonable basis to question impartiality)
Los v. Los, 595 A.2d 381 (Del. 1991) (two‑part test for disqualification: subjective and objective inquiry)
Fritzinger v. State, 10 A.3d 603 (Del. 2010) (recusal and related impartiality analysis)
Gattis v. State, 955 A.2d 1276 (Del. 2008) (standards for judicial disqualification and appearance issues)