Stefanoni v. Darien Little League, Inc., 160 Conn.App. 457

Stefanoni sued Darien Little League for defamation after it disputed her public allegations that the league demoted her son in retaliation for her affordable housing efforts.
The league published a letter to the editor, a website message, and an email to parents denying Stefanoni’s claims and explaining fall-player assignment rules.
At trial, Stefanoni (pro se) mentioned Mark Gregory, a longtime acquaintance and former colleague of the trial judge, prompting the judge to disclose his prior relationship and recess to consider recusal.
Stefanoni asked the judge to recuse; the judge denied the request after hearing both sides and explaining that Gregory had no evident role in the alleged defamation.
The court conducted a full trial, found the league’s statements true or nondefamatory (fair comment) and protected by qualified privilege, and dismissed the complaint.
On appeal Stefanoni challenged only the denial of the recusal request under Code of Judicial Conduct 2.11(a)(1); she did not contest the trial court’s merits findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether judge should have recused under Code 2.11(a)(1) for personal bias or personal knowledge of disputed facts due to his friendship/former association with Mark Gregory	Judge’s prior friendship/association with Gregory and his recent lunch with Gregory create an appearance of partiality; recusal required	Gregory was not a party, counsel, or witness; no pleadings or evidence tying Gregory to the alleged defamatory publications; judge properly disclosed relationship, recessed, heard parties, and afforded plaintiff latitude	Denial of recusal affirmed: no abuse of discretion; a reasonable person would not question impartiality given lack of nexus between Gregory and the dispute, judge’s disclosure, and trial conduct

State v. Rizzo, 303 Conn. 71 (2011) (recusal standard: judge must disqualify where impartiality might reasonably be questioned)
Bonelli v. Bonelli, 214 Conn. 14 (1989) (prior professional contact does not automatically require disqualification; passage of time is relevant)
Joyner v. Commissioner of Correction, 55 Conn. App. 602 (1999) (disclosure by judge of possible conflict supports denial of recusal)
In re Christopher C., 134 Conn. App. 464 (2012) (standard of appellate review for disqualification: abuse of discretion)
State v. Santangelo, 205 Conn. 578 (1987) (burden on moving party to establish appearance of impropriety)
DeMatteo v. DeMatteo, 21 Conn. App. 582 (1990) (speculation and conjecture cannot support recusal)
Tracey v. Tracey, 97 Conn. App. 278 (2006) (speculation insufficient to establish appearance of impropriety)
In re Messiah S., 138 Conn. App. 606 (2012) (appellate review will affirm denial of recusal where findings are supported by evidence)