Order — No. 1:25-cr-00221 (Dkt. 70, N.D. Ga.)
Summary
An order in United States v. Ian Patrick Jackson, Case No. 1:25-CR-00221-ELR, in the U.S. District Court for the Northern District of Georgia, Atlanta Division, filed June 18, 2026 as Document 70 (3 pages), with the signature block of Judge Eleanor L. Ross. The pro se defendant's Motion for Recusal [Doc. 68] cites media coverage of an Eleventh Circuit Judicial Council order (Judicial Compl. No. 11-25-90212) concerning the judge. The Court sets out the disqualification standards of 28 U.S.C. § 455(a) and (b), finds that the defendant identifies no conduct raising a question of impartiality in this case and no ground under § 455(b), and denies the motion.
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“Order — No. 1:25-cr-00221 (Dkt. 70, N.D. Ga.).”
Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/order-no-1-25-cr-00221-dkt-70-n-d-ga-ab0c499df0/
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Case 1:25-cr-00221-ELR-CCB Document 70 Filed 06/18/26 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT FOR THE
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION
UNITED STATES OF AMERICA, *
*
Plaintiffs, *
*
v. * 1:25-CR-00221-ELR
*
IAN PATRICK JACKSON, *
a/k/a L.G., *
a/k/a J.W., *
a/k/a K.B., *
a/k/a J.S., *
*
Defendant. *
*
_________
ORDER
This matter is presently before the Court on Defendant Ian Patrick Jackson’s
Motion for Recusal. [Doc. 68].
Having encountered media coverage about the findings of the Judicial Council
of the Eleventh Judicial Circuit that the undersigned engaged in improper sexual
activity in Chambers during business hours within the hearing of her former law
clerks, see Order, Judicial Compl. No. 11-25-90212 (11th Cir. Judicial Council Feb.
11, 2026)) (“Judicial Council Report”), Defendant, pro se, moves for the recusal of
the undersigned, [Doc. 68 at 1–2]. Defendant asserts that the undersigned’s action
violates codes of judicial conduct and the Georgia Constitution, expresses the view
Case 1:25-cr-00221-ELR-CCB Document 70 Filed 06/18/26 Page 2 of 3
that the undersigned “deserves a more severe punishment than just a private, or even
public, reprimand,” and questions the undersigned’s character and fitness. [Doc. 68
at 2, 5–6].
In accordance with 28 U.S.C. § 455(a), a federal judge must disqualify herself
“in any proceeding in which h[er] impartiality might reasonably be questioned.”
Section 455(b) provides additional circumstances requiring disqualification.1
1
Specifically, § 455(b) provides that a judge
shall also disqualify h[er]self in the following circumstances:
(1) Where [s]he has a personal bias or prejudice concerning a party, or personal
knowledge of disputed evidentiary facts concerning the proceeding;
(2) Where in private practice [s]he served as lawyer in the matter in controversy,
or a lawyer with whom [s]he previously practiced law served during such
association as a lawyer concerning the matter, or the judge or such lawyer has
been a material witness concerning it;
(3) Where [s]he has served in governmental employment and in such capacity
participated as counsel, adviser or material witness concerning the proceeding
or expressed an opinion concerning the merits of the particular case in
controversy;
(4) [Sh]e knows that [s]he, individually or as a fiduciary, or his spouse or minor
child residing in h[er] household, has a financial interest in the subject matter
in controversy or in a party to the proceeding, or any other interest that could
be substantially affected by the outcome of the proceeding;
(5) [Sh]e or h[er] spouse, or a person within the third degree of relationship to
either of them, or the spouse of such a person:
(i) Is a party to the proceeding, or an officer, director, or trustee of a party;
(ii) Is acting as a lawyer in the proceeding;
(iii) Is known by the judge to have an interest that could be substantially
affected by the outcome of the proceeding;
(iv) Is to the judge’s knowledge likely to be a material witness in the
proceeding.
2
Case 1:25-cr-00221-ELR-CCB Document 70 Filed 06/18/26 Page 3 of 3
Defendant fails to show that any of § 455’s circumstances for disqualification are
present here. Defendant identifies no conduct giving rise to a question of the
undersigned’s impartiality in this case, nor does he identify any personal bias,
financial or other interest, or any other cause under § 455(b) justifying the
undersigned’s recusal from this case.
Finding no basis for disqualification, the Court DENIES Defendant’s Motion
for Recusal. [Doc. 68].
SO ORDERED, this 18th day of June, 2026.
_________________________
Eleanor L. Ross
United States District Judge
Northern District of Georgia
3
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