Dianne Hamilton, et al. v. Methodist Healthcare Memphis Hospitals

This is an accelerated interlocutory appeal as of right, pursuant to Tennessee Supreme Court Rule 10B, from the trial court’s denial of a motion for recusal. The plaintiff contends the trial judge should be disqualified because a lawyer with the Lewis Thomason law firm, which represents the defendant in this action, provided a letter of recommendation on behalf of the trial judge in support of the judge’s application for appointment to a vacancy on the Court of Appeals of Tennessee. Plaintiff also contends the trial judge should be disqualified because the judge failed to disclose “the extrajudicial relationship.” Having reviewed the petition for recusal appeal, pursuant to the de novo standard as required under Rule 10B § 2.01, we find that the lawyer who provided the letter of recommendation has no involvement in this case, and that lawyer merely has a de minimis interest in the outcome of this case because the law firm representing the defendant is one of the larger multi-city firms in this state. Based on these facts and the relevant legal principles, we find no basis to conclude that the trial judge’s impartiality might be reasonably questioned. Accordingly, we affirm the trial court’s decision to deny the motion for recusal.