On Wednesday, December 10, 2025, Fix the Court’s Gabe Roth filed a judicial misconduct complaint against Third Circuit Judge Emil Bove following Bove’s attendance at a President Trump rally in Pennsylvania on Tuesday, December 9, 2025. The complaint alleges violations of the Code of Conduct for U.S. Judges.
According to the complaint, Judge Bove was observed at the rally, and when questioned by a reporter, stated he was present “just as a citizen coming to watch the President speak.” However, Roth argues that the event quickly revealed itself to be overtly partisan, with President Trump making statements about serving a third term, disparaging Democrats, and using derogatory terms for former President Biden.
Roth’s complaint acknowledges that there is no inherent prohibition against a federal judge attending an event where the President is speaking, such as the State of the Union address. However, the core of the complaint rests on the assertion that once it became evident the rally was a “highly charged, highly political event,” Judge Bove should have recused himself from the situation.
The complaint specifically cites two canons of the Code of Conduct for U.S. Judges that Roth believes were violated. The first is Canon 2, which mandates that a judge “should avoid impropriety and the appearance of impropriety in all activities.” Roth argues that attending a partisan Trump rally constitutes a clear violation of this canon.
The second canon cited is Canon 5, which states that a judge “should refrain from political activity.” Given the rally’s resemblance to a Trump campaign event, Roth contends that Judge Bove’s presence also violated this canon.
Roth has formally requested that Chief Judge Michael A. Chagares investigate the claims made in the complaint and take appropriate disciplinary action against Judge Bove under the Judicial Conduct and Disability Act.
A copy of the original filing can be found here.
