In Re: Conservatorship of John Daniel Tate
This case concerns an interlocutory appeal of right from the denial of a motion for recusal in a conservatorship proceeding for John Daniel Tate. Mr. Tate argued the trial judge exhibited personal bias due to contentious litigation, adverse rulings, his public criticism via a blog, and a federal lawsuit he filed against the judge. The Court of Appeals of Tennessee, reviewing de novo under Rule 10B, found no reasonable basis to question the judge's impartiality. The court affirmed the trial court's decision, noting that adverse rulings and a litigant's actions to force recusal are generally insufficient grounds for disqualification. Additionally, the court found no procedural errors regarding the promptness or written explanation of the denial, and dismissed other jurisdictional claims as outside the scope of a Rule 10B appeal.