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In re: Walter Leroy Moody, Jr.

Citation: Not availableDocket: 13-12657

Court: Court of Appeals for the Eleventh Circuit; January 9, 2014; Federal Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

This case involves Walter Leroy Moody, Jr., who petitioned for a writ of mandamus for the recusal of District Judge L. Scott Coogler from his federal habeas corpus petition. Moody, convicted of the 1989 murder of Judge Robert S. Vance, argued for the recusal of all Eleventh Circuit judges due to potential partiality under 28 U.S.C. §§ 455(a) and 455(b)(4). Previously, all judges within the Circuit recused themselves from related cases, but the current panel, having no direct ties to Judge Vance or the incident, declined recusal. Moody's appeal of his conviction was affirmed, and his recusal motion was denied. The court held that the judges' connection to the case did not warrant recusal, as their impartiality was not reasonably questionable, and their interest was deemed remote. The petition for mandamus was denied, with the court finding no abuse of discretion by Judge Coogler. The opinion emphasized adherence to recusal standards, balancing the need to recuse with the duty to remain when not justified, asserting confidence in Judge Coogler's impartiality in handling the habeas corpus petition.

Legal Issues Addressed

Mandamus as an Extraordinary Remedy

Application: The court denied Mr. Moody's petition for mandamus, finding no clear abuse of discretion by Judge Coogler in refusing to recuse himself.

Reasoning: The Supreme Court emphasizes that mandamus is an extraordinary remedy, applicable only in cases of clear abuse of discretion or usurpation of power.

Precedent and Recusal

Application: The court found that precedent such as In re Nettles did not apply, as the judges were not potential victims of a crime in this case.

Reasoning: Mr. Moody's reliance on In re Nettles is misplaced, as that case involved judges potentially seen as victims of a crime, unlike the present case where no such allegations exist.

Recusal Under 28 U.S.C. § 455(a)

Application: The court determined that recusal was not necessary for the judges of the Eleventh Circuit as their connection to the case did not create a reasonable question of impartiality.

Reasoning: Recusal decisions hinge on whether a reasonable observer would doubt a judge's impartiality based on presented facts.

Recusal Under 28 U.S.C. § 455(b)(4)

Application: The court held that the judges did not have a substantial interest affected by the outcome of the proceeding, as their connections to the events in question were deemed remote.

Reasoning: Interest in the case is deemed remote and weak, not warranting disqualification or significant influence on the outcome of Mr. Moody’s habeas corpus proceeding.