Troja v. Pleatman, 145 Ohio St. 3d 1226

Defendant Jacqueline (Crysta) Pleatman filed an affidavit under R.C. 2701.03 seeking to disqualify Judge Jody Luebbers from a breach-of-contract case.
Pleatman alleged judicial bias, claiming threats of jail for emails she sent to opposing parties and counsel, a May 2015 hearing in which the judge "screamed" at her, and other improper rulings (attorney-fee awards, dismissal of third-party defendants, and issuance of a nunc pro tunc order).
Judge Luebbers submitted a written response denying bias, explaining legal bases for rulings, denying she screamed, and describing the nunc pro tunc entry as inadvertent error.
The Chief Justice considered only whether disqualifying bias, prejudice, or other disqualifying interest was shown — not the correctness of the judge’s legal rulings.
The court emphasized that an affidavit of disqualification is not the proper vehicle to challenge substantive or procedural rulings, which must be pursued through ordinary appellate or trial-court remedies.
The Chief Justice found the presumption that judges follow the law and are impartial was not overcome and denied the affidavit; the case may continue before Judge Luebbers.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Judge Luebbers is biased and must be disqualified	Pleatman: judge threatened jail for her emails, screamed at her, and demonstrated bias through rulings	Judge Luebbers: denies bias; rulings were lawful and any perceived incident (screaming) did not occur	Denied — record does not show disqualifying bias or prejudice
Whether First Amendment rights were violated by threats of jail for emails	Pleatman contends threats chilled her communications to resolve the case	Judge says actions were lawful court-management measures; denies violating rights	Not resolved on merits here; affidavit cannot be used to litigate constitutional claims in place of appeal; no bias shown
Whether the nunc pro tunc order was improper	Pleatman claims the nunc pro tunc entry was improper and evidences misconduct	Judge explains the entry resulted from inadvertent error and corrects the record	No basis to disqualify; merits of the nunc pro tunc order are not decided in disqualification proceeding
Whether substantive or procedural rulings (fees, dismissals) support disqualification	Pleatman points to fee awards and dismissals as evidence of prejudice	Judge maintains rulings were legally based; such errors are for appeal, not disqualification	Errors in law or procedure do not alone establish disqualifying bias; affidavit denied

In re Disqualification of Griffin, 803 N.E.2d 820 (Ohio 2003) (affidavit of disqualification is not the mechanism to determine whether a judge complied with the law)
In re Disqualification of Solovan, 798 N.E.2d 3 (Ohio 2003) (same — affidavit of disqualification cannot be used to contest substantive or procedural rulings)
In re Disqualification of Kate, 723 N.E.2d 1098 (Ohio 1999) (chief justice’s role limited to determining whether disqualifying bias, prejudice, or interest exists)
In re Disqualification of George, 798 N.E.2d 23 (Ohio 2003) (judges are presumed impartial; appearance of bias must be compelling to overcome the presumption)