Deutsche Bank National Trust Co. v. Nichols

Illinois Appellate Court
Civil Court
Citation
Case Number: 
2013 IL App (1st) 120350
Decision Date: 
August 30, 2013
District: 
1st Dist.
Division/County: 
Cook Co., 6th Div.
Justice: 
REYES
Holding: 
Affirmed.
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.)