On Friday, October 3, 2025, nonprofit organization Fix the Court released an update to its July report, “Conflict U.,” which examined instances of federal judges not recusing themselves from cases involving universities where they also served as law school instructors. The update reveals that some judges are, in fact, choosing to recuse themselves in such cases, and in at least one instance, due to a spousal connection to a university.

The original “Conflict U.” report identified 24 federal judges who did not recuse themselves in six dozen cases involving universities where they held positions as law school instructors. Fix the Court argued that this practice raises conflict-of-interest concerns, even though it is permitted under current judiciary policy. The report advocated for reforms to strengthen recusal practices and bolster public trust in judicial ethics.

The follow-up research conducted by Fix the Court uncovered several instances of judges recusing themselves from cases involving universities with which they had affiliations.

In June 2025, Judge Brian Buescher of the District of Nebraska recused himself in the case of Mohammed v. Creighton University. This recusal is believed to be due to his role as an instructor at Creighton University School of Law. The case was initially filed on December 9, 2024, with the last filing on June 3, 2025, and the recusal order was entered on June 2, 2025.

In May 2025, Magistrate Judge Anna Howard of the Northern District of Georgia recused herself in Manuel v. Georgia State University. The case was filed on May 5, 2025, with the last filing on June 16, 2025, and the recusal order was entered on May 6, 2025. Howard’s LinkedIn profile indicates that she teaches at the University of Georgia School of Law, which, along with Georgia State, is part of the University System of Georgia.

In April 2025, Judge William G. Young of the District of Massachusetts recused himself in Curtin-Wilding v. Trustees of Boston University. The case was filed on February 21, 2025, with the last filing on August 27, 2025, and the recusal order was entered on April 29, 2025. The recusal is believed to be related to Young’s prior teaching position at Boston University School of Law from 1979 to 2020, as mentioned in the defendant’s motion for recusal.

Also in April 2025, Judge John Koeltl of the Southern District of New York recused himself in Thomas v. New York University. The case was filed on March 26, 2025, with the last filing on June 20, 2025, and the recusal order was entered on April 1, 2025. The recusal is likely due to his position as an adjunct at NYU School of Law.

In December 2024, Judge Hope Cannon of the Northern District of Florida recused herself in Robinson v. University of West Florida. The case was filed on December 6, 2024, with the last filing and recusal order entered on December 9, 2024. The recusal is possibly linked to her role as an adjunct professor of criminology at UWF, although this affiliation is not listed on her financial disclosure reports.

In October 2024, Magistrate Judge Jonathan Goodman of the Southern District of Florida recused himself in Comack v. University of Miami. The case was filed on September 6, 2024, with the last filing on June 20, 2025, and the recusal order entered on October 7, 2024. The plaintiff’s motion cited Goodman’s status as a University of Miami School of Law alumnus, but the judge also mentioned his role as an adjunct instructor at Miami Law in his recusal order. Goodman retired from the bench in July 2025.

In April 2024, Judge Scott Palk of the Western District of Oklahoma recused himself in Olupitan v. Board of Regents at the University of Oklahoma. The case was filed on April 8, 2024, with the last filing on August 15, 2025, and the recusal order entered on April 9, 2024. The recusal is likely due to his wife’s position as deputy general counsel at the University of Oklahoma.

Fix the Court stated they will continue to investigate these matters and hopes the committee and the public will recognize that while some judges are committed to avoiding conflicts of interest, others are not, and that reform is necessary to ensure consistency across the judiciary.

 

 

Source: Fix the Court