Frazier v. Bruce

Summary

The Oklahoma Supreme Court denied Mia Frazier's request to disqualify a district court judge after the judge granted a continuance of a hearing on visitation enforcement. The Court held that an alleged legal error was insufficient grounds for disqualification and characterized the filing as frivolous and intended to delay proceedings. It granted the real party in interest's motion for attorney fees and authorized the district court to determine a reasonable sanction.

Holdings

1. A mere mistake in a court's legal ruling is not grounds for judicial disqualification; Frazier's challenge to the continuance therefore provided an insufficient basis for disqualification.
2. A filing invoking the Supreme Court's original jurisdiction to disqualify a judge is frivolous when its sole basis is a ground the Court has routinely rejected, and sanctions may be imposed when the filing was also made to delay or disrupt the underlying proceedings.
3. The district court was authorized to hold an evidentiary hearing to determine the reasonable attorney fee to award to Benavidez as a sanction against Frazier.

Questions Presented

1. Whether a judge's allegedly erroneous continuance order constituted grounds for judicial disqualification under Rule 15.
2. Whether Frazier's disqualification filing was frivolous and intended to delay or disrupt the underlying proceedings, warranting an attorney-fee sanction.
3. Whether the district court could conduct an evidentiary hearing to determine the reasonable amount of attorney fees awarded as a sanction.

Disposition

other