Ryan Scott Adams v. State of Washington

Summary

The United States District Court for the Western District of Washington declines a magistrate judge’s voluntary recusal in Ryan Scott Adams’s 28 U.S.C. § 2254 action. The court concludes that the petitioner’s cited rulings and alleged conduct do not establish a reasonable basis to question the judge’s impartiality, refers the recusal motion to the chief judge, and re-notes several motions for February 13, 2026.

Holdings

1. Prior judicial rulings, including rulings adverse to the petitioner in the present or a separate case, did not establish a reasonable basis to question the magistrate judge's impartiality or require recusal.
2. The denial of habeas discovery did not support recusal because habeas petitioners do not have a presumptive entitlement to discovery and the court had not found good cause for discovery at that stage.

Questions Presented

1. Whether the magistrate judge was required to recuse under 28 U.S.C. §§ 144 or 455 based on prior judicial rulings and alleged predisposition.
2. Whether the magistrate judge should voluntarily recuse under Local Civil Rule 3(f).

Disposition

other