## Facts

- John A. Liljeberg, Jr. formed St. Jude Hospital of Kenner, Inc. to pursue a state certificate of need to build and operate a hospital in Kenner, Louisiana.
- Liljeberg negotiated with Loyola University to buy Loyola-owned land as a hospital site; Loyola’s economic interest depended on the certificate of need associated with the project.
- The federal trial judge, Judge Robert Collins, served as a trustee of Loyola University; the Loyola board regularly discussed the negotiations connected to the hospital project.
- Health Services Acquisition Corp. (as successor to Hospital Affiliates International) believed an agreement with Liljeberg transferred title to St. Jude to it, and it pursued the certificate process using a different site.
- Health Services filed a federal action seeking a declaration that it owned St. Jude; Judge Collins conducted a bench trial and entered judgment for Liljeberg, resolving key factual disputes by crediting Liljeberg’s account.
- After the merits appeal was affirmed, Health Services discovered Judge Collins’s Loyola trusteeship and moved to vacate the judgment under Fed. R. Civ. P. 60(b)(6), asserting a disqualification violation under 28 U.S.C. § 455(a).

## Issues

1. Whether 28 U.S.C. § 455(a) is violated when a judge fails to recuse despite an undisclosed institutional relationship that would cause a reasonable observer to question impartiality, even absent actual contemporaneous knowledge of the conflict.
2. Whether, and under what standards, a final judgment may be vacated under Fed. R. Civ. P. 60(b)(6) based on a § 455(a) violation.

## Decision

- The Supreme Court held that Judge Collins’s participation was a violation of 28 U.S.C. § 455(a) because his impartiality might reasonably be questioned given his Loyola trusteeship and Loyola’s concrete interest tied to the litigation’s subject matter.
- The Court held that vacatur under Fed. R. Civ. P. 60(b)(6) was an available and appropriate remedy on the facts presented.
- The Court affirmed the appellate judgment requiring that the district court judgment be set aside and the matter retried before a different judge.

## Legal Principles

- Section 455(a) applies an objective standard: disqualification is required when a reasonable person, informed of the relevant circumstances, would question the judge’s impartiality.
- A § 455(a) violation does not require proof of actual bias, improper motive, or the judge’s subjective awareness of all disqualifying facts at the time of adjudication.
- An institutional affiliation (such as board membership) with an entity holding a significant stake connected to the litigation can create a disqualifying appearance even if the entity is not a named party.
- Rule 60(b)(6) relief for a § 455(a) violation is equitable and case-specific; relevant considerations include (1) risk of injustice to the parties, (2) risk of injustice in other cases from underenforcement or strategic delay, and (3) risk of undermining public confidence in the judiciary.

## Conclusion

The Court ruled that the appearance-of-impartiality standard in § 455(a) required recusal based on the judge’s institutional relationship to an interested entity and that, applying equitable factors, Rule 60(b)(6) permitted vacating a final judgment to protect fairness and public confidence in the courts.


Liljeberg v. Health Servs. Acquisition Corp., 486 U.S. 847 (1988)