On Thursday, July 31, 2025, nonprofit organization Fix the Court published a report titled “Conflict U.: Two Dozen Federal Judges Did Not Recuse in Cases Involving the Universities Where They Teach.”
The report highlights that 24 federal judges across the United States have presided over more than 70 cases involving universities where they serve as adjunct professors, without recusing themselves. The findings, described as illustrative rather than exhaustive, indicate that this issue spans 10 of the 13 federal judicial circuits.
The report identifies several prominent universities where these judges teach, including Yale University, Ohio State University, the University of Miami, the University of Notre Dame, and the University of Texas at Austin. Many of the cases involve judges who are part-time law school instructors ruling on matters concerning the parent university of their respective law schools.
Among the judges listed in the report are Wendy Beetlestone of the Third Circuit in Pennsylvania, affiliated with the University of Pennsylvania; Victor Bolden of the Second Circuit in Connecticut, teaching at Yale University; Sara Ellis of the Seventh Circuit in Illinois, connected to Loyola University Chicago; John Koeltl of the Second Circuit in New York, associated with New York University; Robert Levy of the Second Circuit in New York, linked to Columbia University; Algenon Marbley of the Sixth Circuit in Ohio, teaching at Ohio State University; Robert Pitman of the Fifth Circuit in Texas, affiliated with the University of Texas at Austin; Zahid Quraishi of the Third Circuit in New Jersey, connected to Seton Hall University and Rutgers University; Jolie Russo of the Ninth Circuit in Oregon, teaching at the University of Oregon; Edmund Sargus of the Sixth Circuit in Ohio, associated with Ohio State University; Michael Shipp of the Third Circuit in New Jersey, linked to Seton Hall University; and Patty Shwartz of the Third Circuit in New Jersey, affiliated with Rutgers University.
The report points out that the failure to recuse in these cases raises concerns about potential bias, as a judge’s affiliation with a university could be perceived as influencing their impartiality. It notes that even when judges claim the law school is a distinct entity within the university, their role as adjunct faculty could still create an appearance of impropriety.
In contrast, the report commends Supreme Court Justices Neil Gorsuch and Amy Coney Barrett for their recusal practices. Both justices, who previously taught at law schools, have recused themselves from cases involving the parent universities of those schools, demonstrating a stricter approach to avoiding conflicts of interest.
To address the issue, the report suggests potential reforms, such as amending the U.S. Guide to Judiciary Policy to mandate recusals in cases involving a judge’s affiliated university. Another recommendation is for judges to include universities on their recusal lists. Additionally, it proposes that judges disclose their teaching affiliations in the docket of any university-related case and allow parties to object to their continued involvement.
Fix the Court, which focuses on increasing judicial accountability, emphasizes that while teaching as an adjunct is permissible, judges should consider their ethical obligations when presiding over cases involving their universities.
