From Markle v. Markle, decided today by Judge Charlene Edwards Honeywell (M.D. Fla.); seems quite correct to me (see here for the substantive issue in the case):
In this action, Samantha Markle sues Meghan, the Duchess of Sussex, for defamation and injurious falsehood. She now seeks the undersigned's disqualification under 28 U.S.C. § 455(a)….
Samantha Markle seeks disqualification because President Barack Obama appointed the undersigned to serve as a federal judge in 2009. She asserts that "there exists a reasonable basis that [the undersigned's] impartiality will be questioned" because President Obama appointed the undersigned and "the Obama family, Prince Harry, and Meghan are 'allies' and strong supporters of one another." She also highlights that the Duchess met privately with First Lady Michelle Obama in 2018 and, in 2020, co-chaired a voter-registration drive with the former first lady, whom the Duchess called her "friend."
In addition to describing Prince Harry and President Obama as "allies," Markle asserts that Prince Harry visited the former president in the White House, welcomed the former president and former first lady to Kensington Palace, and conducted "an intimate interview" with the former president. Finally, she contends that the Duchess and the former president "share the same communications team lead."
The Motion to Disqualify lacks merit. Despite arguing that members of the public would entertain a "significant doubt" as to the undersigned's impartiality because "there seems to be an undeniable connection" between the Obamas and the Duchess, Markle concedes that she "is unaware if [the undersigned] has a current relationship with Obama, and how far back the relationship has existed." Of course, a valid recusal request may not lack factual support, nor may a party premise a recusal request upon unsupported or highly tenuous speculation.
