Reyes Ex Rel. Reyes v. Infinity Indemnity Insurance Co., 221 So. 3d 775

Reyeses filed a verified motion to disqualify the trial judge, alleging grounds for recusal tied to the judge/spouse relationships with parties or their counsel.
The trial court denied recusal; Reyeses sought a writ of prohibition from the district court.
The district court found the sworn statements in the verified motion legally insufficient under Fla. R. Jud. Admin. 2.330 to require recusal.
The petition also failed to allege when Reyeses discovered the facts forming the basis for disqualification, so timeliness under the rule could not be established.
Reyeses later filed a reconsideration motion with new allegations that companies managed by the judge’s spouse were the real plaintiffs in unrelated suits against a client of the Reyes’ opposing firm, suggesting a financial interest by the judge/spouse.
The court deemed those new allegations untimely (filed more than ten days after discovery) but noted that a judge may still voluntarily recuse under rule 2.330(i).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the verified motion contained legally sufficient sworn statements to require recusal under Fla. R. Jud. Admin. 2.330	Reyeses argued the judge had disqualifying connections and financial interest via spouse-related entities	Trial judge (and respondent) argued the verified statements were legally insufficient to mandate recusal	Motion was legally insufficient; petition for writ of prohibition denied
Whether the disqualification allegations were timely (when discovery occurred)	Reyeses contended alleged facts warranted disqualification; later allegations claimed spouse-managed companies were actual plaintiffs in related suits	Court emphasized rule 2.330’s timeliness requirement and that the motion failed to state when facts were discovered	New allegations were untimely (filed >10 days after discovery); court refused writ but noted judges may self-recuse under rule 2.330(i)

Kormondy v. State, 983 So. 2d 418 (Fla. 2007) (affirming denial where claim of judicial connection was insufficient to require recusal)
State v. Oliu, 183 So. 3d 1161 (Fla. 3d DCA 2016) (noting rule 2.330(i) allows a judge to disqualify on own initiative)
Carlton v. Rogers (In re Estate of Carlton), 378 So. 2d 1212 (Fla. 1979) (judge may voluntarily recuse even if suggestion legally insufficient)
Aurigemma v. State, 964 So. 2d 224 (Fla. 4th DCA 2007) (granting prohibition where judge’s spouse had repeated professional ties creating risk of bias)
Howard v. State, 950 So. 2d 1260 (Fla. 5th DCA 2007) (motion to disqualify untimely where it failed to allege when the allegedly disqualifying comments occurred)