I. This case presents a substantial federal due process question.
The Fourteenth Amendment requires an impartial tribunal. A judge who maintained a 14-year
professional partnership with a law firm that is now a defendant creates, at minimum, an
appearance of bias sufficient to undermine confidence in the proceedings. See Caperton v. A.T.
Massey Coal Co., 556 U.S. 868 (2009).

II. The decision below misapplies the federal constitutional standard for recusal.
The Tennessee courts dismissed the recusal request as "speculation, " contrary to this Court 's
ordinary-person perception test. Caperton makes clear that due process is violated where the
probability of bias is too high to be constitutionally tolerable.

III. Lower courts are divided and uncertain on the treatment of historical professional
relationships.
Some courts treat longstanding professional ties as disqualifying, while others dismiss them as
remote. This lack of uniformity invites inconsistent protection of litigants ' due process rights
across the states.

IV. The refusal to acknowledge the affidavit compounds the constitutional violation.
The state courts incorrectly stated that no affidavit was filed, disregarding a sworn filing in the
record. This denial of record consideration itself violates procedural due process.

V. This case presents a recurring and nationally significant problem.
Judges frequently have longstanding ties with law firms or parties that later appear before them.
Without clarification from this Court, litigants across the country face uncertainty and unequal
protection of their constitutional right to an impartial tribunal.

Whether a judge's 14-year professional partnership with a law firm now appearing as a defendant creates an unconstitutional appearance of bias under the Fourteenth Amendment's due process requirements