Here’s an analysis of In re Stillwater Capital, the recusal versus disqualification case from the Dallas Court of Appeals May 15, 2025, breaking down what happened and why the court reached its decision. You can read the opinion by clicking here.
Case Overview
- Court: Fifth District Court of Appeals, Dallas, Texas
- Case Title: In re Stillwater Capital Investments, LLC, et al.
- Date: May 15, 2025
- Type: Original proceeding (writ of mandamus)
What Happened?
- Litigation Begins: The underlying lawsuit started in a Texas district court, presided over by a judge who later moved to a different court (the 162nd District Court).
- Judge’s Actions: While assigned, this judge made several rulings—on things like discovery, scheduling, evidence, and summary judgment.
- Judge Recuses Herself: On the first day of trial, the judge orally recused herself (i.e., stepped down from the case) and later signed a formal recusal order.
- Case Transferred: The Presiding Judge (who oversees administrative matters for the region) transferred the case to a new court.
- Judge’s Term Ends: The original judge’s term expired at the end of 2024.
The Parties’ Complaint
- Relators (Stillwater, et al.): After the judge recused herself and after the transfer, they filed a motion to have the judge disqualified (which is a higher bar than recusal) and to void all her prior orders.
- Their Argument: They believed the judge should be declared disqualified, not just recused, and that all her rulings (and those by an associate judge she appointed) should be wiped out.
- They also wanted: A hearing on their motion, as required by Texas Rule of Civil Procedure 18a.
What Did the Presiding Judge Do?
- Denied the Motions: The Presiding Judge denied the relators’ motion to disqualify and their request for a hearing, calling the issue “moot” (because the judge had already recused and her term was over).
- Second Motion: Relators tried again, filing an amended motion for an evidentiary hearing. The Presiding Judge again denied it before any hearing took place.
The Appeal (Mandamus)
- Mandamus Petition: Relators asked the Court of Appeals to force the Presiding Judge to (a) declare the judge disqualified and void all her orders, or (b) at least hold a hearing.
The Court of Appeals’ Reasoning
- Rule 18a’s Purpose: This rule lets parties ask to recuse or disqualify a sitting judge to ensure fairness. But here, by the time the relators asked for disqualification, the judge had already recused herself and was no longer involved.
- No Need for Hearing: Since the judge was already gone, there was nothing left for the Presiding Judge to do—no relief to grant under Rule 18a.
- Disqualification vs. Recusal: Disqualification is more serious (and voids all orders), but relators waited until after the judge recused and her term expired to raise the issue.
- Who Decides If Orders Are Void?: The trial court (now the 193rd District Court) can decide if the previous orders are void due to disqualification. The Presiding Judge is not the right forum.
- Mandamus Standard: To get mandamus relief, you must show the judge clearly abused their discretion and you have no other remedy. Here, relators can still raise their arguments with the trial court.
The Bottom Line
- Mandamus Denied: The Court of Appeals refused to grant the writ. The relators did not show the Presiding Judge abused discretion in denying the hearings or their motions.
- What’s Next?: If relators still want to challenge the former judge’s rulings as void, they need to do that in the new trial court.
Summary The court said: You waited too long to challenge the judge. She was already gone, so the Presiding Judge didn’t need to hold a hearing or declare her disqualified. If you think her rulings are void, take it up with the current trial court—not us.
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