Deutsche Bank National Trust Co. v. Nichols

Illinois Appellate Court
Civil Court
Case Number: 
2013 IL App (1st) 120350
Decision Date: 
August 30, 2013
1st Dist.
Cook Co., 6th Div.
Pro se defendant filed appeal challenging order approving sale, after default judgment of foreclosure and confirmation of sale was entered. Defendant’s filing of a for-cause motion for substitution of judge did not require judge to immediately suspend all pending issues in a matter, as otherwise such motion would become a vehicle for delay. Motion failed to allege any bias stemming from extrajudicial source. A judge’s previous rulings can be valid basis for claim of judicial bias only if they reveal opinion that derives from an extrajudicial source or such a high degree of favoritism or antagonism as to make fair judgment impossible. (HALL, concurring; GORDON, dissenting.)