Third Circuit disposition — 261792np-pdf

CLD-114 NOT PRECEDENTIAL
UNITED STATES COURT OF APPEALS
FOR THE THIRD CIRCUIT
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No. 26-1792
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IN RE: JAKE BYLSMA,
Petitioner
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On a Petition for Writ of Mandamus from the
United States District Court for the Middle District of Pennsylvania
(Related to M.D. Pa. No. 1:23-cv-00038)
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Submitted Pursuant to Rule 21, Fed. R. App. P.
April 16, 2026
Before: BIBAS, PHIPPS, and NYGAARD, Circuit Judges
(Opinion filed: April 29, 2026)
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OPINION*
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PER CURIAM
In January 2023, the petitioner, Jake Bylsma, commenced a civil rights action in
the District Court against several individuals involved in proceedings against him in the
Adams County Court of Common Pleas. After the District Judge granted one of the
defendants’ motions to dismiss, she permitted Bylsma’s attorney to withdraw. Bylsma
then moved to disqualify the District Judge for actual bias under 28 U.S.C. § 144 and for
* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not
constitute binding precedent.

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the appearance of impartiality under § 455. The District Judge declined to recuse herself
from the case. Bylsma then filed a petition for a writ of mandamus in this Court asking
us to compel her recusal. We denied the petition. In re: Jake Bylsma, C.A. No. 25-1307
(order entered Mar. 11, 2025).
The case then proceeded in the District Court, where the District Judge gave
Bylsma an opportunity to file an amended complaint. Rather than doing so, however, he
filed another motion to disqualify her. She again denied relief.
Bylsma has now filed a second mandamus petition in this Court asking us to
compel the District Judge’s recusal under §§ 144 and 455. He alleges that the District
Judge has not read the contents of his filings and has dismissed his motions “in an effort
to conceal a real estate and bankruptcy fraud racket operated by her fellow Pennsylvania
judicial elite.” Pet. 7, ECF No. 1-3.
We will deny the petition. First, to the extent that Bylsma challenges the District
Judge’s refusal to disqualify herself for actual bias under § 144, we cannot review her
ruling via mandamus. See In re Sch. Asbestos Litig., 977 F.2d 764, 776 (3d Cir. 1992)
(citation omitted). Second, to the extent that he sought recusal based on an appearance of
partiality under § 455, nothing in the record leads us to question her impartiality. See In
re Kensington Int’l Ltd, 368 F.3d 289, 301 (3d Cir. 2004). Bylsma’s mere disagreement
with the District Judge’s rulings is not an adequate basis for recusal. See Securacomm
Consulting, Inc. v. Securacom Inc., 224 F.3d 273, 278 (3d Cir. 2000).

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Accordingly, we will deny the mandamus petition.1
1 In light of our ruling, we deny Bylsma’s request for a stay of the District Court
proceedings pending resolution of this petition.

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