PRECEDENTIAL

UNITED STATES COURT OF APPEALS

FOR THE THIRD CIRCUIT 

_____________

No. 18-2272

_____________

SHENECQUA BUTT; ALLEGRA KING; TANYA 

MITCHELL; THERESA HOWARD; ELLEN BRONSON

v.

UNITED BROTHERHOOD OF 

CARPENTERS & JOINERS OF AMERICA; 

CARPENTERS HEALTH & WELFARE FUND OF 

PHILADELPHIA & VICINITY; EDWARD CORYELL; 

MARK DURKALEC; PHILADELPHIA HOUSING 

AUTHORITY; METROPOLITAN REGIONAL COUNCIL 

OF CARPENTERS AND JOINERS OF AMERICA

SANDRA THOMPSON,

Appellant

_____________

No. 18-2273

_____________

THERESA HOWARD

v.
2

PHILADELPHIA HOUSING AUTHORITY; 

METROPOLITAN REGIONAL COUNCIL OF 

CARPENTERS AND JOINERS OF AMERICA; EDWARD 

CORYELL, SR. (OFFICIALLY AND PERSONALLY); 

MARK DURKALEC (OFFICIALLY AND PERSONALLY)

SANDRA THOMPSON,

Appellant 

_____________

On Appeal from the United States District Court

for the Eastern District of Pennsylvania

District Court Nos. 2-09-cv-04285; 2-13-cv-00374

Magistrate Judge: The Honorable David R. Strawbridge 

_____________

Submitted on November 12, 2020

Before: HARDIMAN, SCIRICA, and RENDELL, Circuit 

Judges

(Filed: June 8, 2021)

Sandra Thompson

Law Office of Sandra Thompson, LLC

351 E. Princess Street

P.O. Box 1901

York, PA 17405

Counsel for Thompson, Appellant
3

Ryan M. Paddick

1442 Pottstown Pike, #312

West Chester, PA 19380

Counsel for Paddick, Appellee

________________

OPINION OF THE COURT

________________

HARDIMAN, Circuit Judge.

This appeal involves a dispute over legal fees. The 

District Court ordered attorney Sandra Thompson to pay 

predecessor counsel, Ryan Paddick, $54,562.73 from 

Thompson’s portion of a settlement fund. Thompson appealed, 

raising four arguments. We will affirm. 

I

This controversy between attorneys Thompson and 

Paddick began over a decade ago. In 2009 and 2010, 

Shenecqua Butt, Theresa Howard, and Ellen Brown 

(collectively, the Clients), filed separate discrimination cases

in the United States District Court for the Eastern District of 

Pennsylvania against, among others, the United Brotherhood 

of Carpenters & Joiners of America. After their cases were 

consolidated for discovery, the Clients suffered an adverse 

summary judgment in January 2012. Acting pro se, the Clients 

filed a notice of appeal in this Court.

The Clients then hired Paddick to handle their Third 

Circuit appeal. The night before the case was scheduled for oral 

argument, Paddick entered into contingency fee agreements 
4

with each of the Clients. Those agreements provided that 

Paddick would serve as counsel on remand (if any) and 

promised Paddick a 40 percent fee of any trial or settlement

proceeds. 

Paddick prevailed in the appeal. Consistent with his 

agreement with the Clients, Paddick pursued discovery and 

prepared for trial. Paddick took twenty-four depositions, 

presented two oral arguments, attended two settlement 

conferences, and filed nine substantive motions or responses. 

When it came time to retain an expert witness in March 2015, 

however, Paddick was unable to advance the necessary funds. 

Paddick told the Clients: “if this puts you in a position where 

you feel the need to change counsel, I will cooperate with any 

new counsel.” Paddick v. Butt, 2018 WL 1991737, at *10 (E.D. 

Pa. Apr. 27, 2018). 

In April 2015, the Clients terminated their relationship 

with Paddick and retained Thompson to pursue their claims for

a 35 percent contingent fee. Paddick informed Thompson of 

his labors on behalf of the Clients and told her that “fees remain 

due on the work [he] did on the cases prior to [her] stepping 

in.” Id. at *10. Thompson did not respond. In September 2017, 

the Clients settled their cases for a total of $380,000, so under 

her fee agreement, Thompson’s share was $133,000. 

In October 2017, the District Court acknowledged the 

settlements and dismissed the Clients’ cases with prejudice. 

About a month later, Paddick moved to intervene in the 

Clients’ cases to enforce an attorney’s charging lien against the 

settlement proceeds. The District Court granted Paddick’s 

motion to intervene, set a hearing date, and ordered Thompson 

to hold the contested portion of the settlement proceeds in an 

escrow account “pending resolution of the motion.” Dist. Ct. 
5

Dkt. No. 321, at 2. In April 2018, the District Court found 

Paddick entitled to $54,562.73 for his work and ordered 

Thompson to pay Paddick that amount in her capacity as 

custodian of the escrow account. Dist. Ct. Dkt. No. 357, at 1.

The District Court’s order did not, however, explicitly state 

whether Paddick’s fees were to be paid from the fees paid to 

Thompson or from the Clients’ portion of the settlement fund. 

Confusion ensued between Thompson and the Clients, so the 

District Court held a second hearing in May 2018 to resolve 

the matter. Thompson argued Paddick’s fee should not come 

from her fees but instead should come from the Clients’ portion 

of the recovery.

1 The District Court disagreed and ordered 

Thompson to pay Paddick’s fee from her $133,000 portion. 

Thompson filed this timely appeal.

II2

Thompson’s first (and most substantial) argument is 

that the District Court lacked jurisdiction to hear Paddick’s 

1 Thompson’s argument led to a Public Reprimand by the 

Disciplinary Board of the Supreme Court of Pennsylvania. The 

Disciplinary Board determined Thompson violated seven 

ethical Rules of Professional Conduct (RPC) related to her 

representation, including RPC 1.7(a)(2) for acting adversely to 

her Clients when she “maintained that her legal fees were 

separate and apart from prior counsel’s legal fees.” App. 840.

Thompson filed this appeal on her own behalf, not as counsel 

to the Clients.

2 We have jurisdiction under 28 U.S.C. § 1291 and review de 

novo the District Court’s exercise of jurisdiction. In re Cmty. 
6

motions. She claims the Court’s jurisdiction “terminated” 

when the cases were dismissed with prejudice after settlement. 

Butt Br. 30. Thompson acknowledges that the District Court 

had the “inherent power to enforce its judgments.” Butt Br. 31 

(quoting Peacock v. Thomas, 516 U.S. 349, 359 (1996)). But 

she contends that Paddick must seek to enforce his attorney’s 

lien by suing the Clients in state court because the District 

Court did not retain jurisdiction over the case after it was 

dismissed and Paddick did not seek to intervene before the 

dismissal.

We disagree. The District Court had jurisdiction to 

resolve Paddick’s lien motion, but not for the reason it cited 

(i.e., the supplemental jurisdiction statute, 28 U.S.C. § 1367).

As we shall explain, the District Court had ancillary 

enforcement jurisdiction based on its inherent powers rooted in 

the common law and unrelated to the statutory grant of 

authority. 

Courts, including this one, have sometimes been 

imprecise when discussing ancillary enforcement jurisdiction. 

See, e.g., IFC Interconsult v. Safeguard Int’l Partners, LLC, 

438 F.3d 298, 309 (3d Cir. 2006) (treating the inquiries for 

ancillary and supplemental jurisdiction as the same); 13 

CHARLES ALAN WRIGHT & ARTHUR R. MILLER, FEDERAL 

PRACTICE AND PROCEDURE § 3523 (3d ed. 2002) (“Today, the 

terms ‘ancillary,’ ‘pendent,’ and ‘supplemental’ are all used, 

essentially interchangeably.”). This appeal provides us an 

Bank of N. Va. Mortg. Lending Pracs. Litig., 911 F.3d 666, 670 

(3d Cir. 2018).
7

opportunity to clear up “needless confusion,” WRIGHT &

MILLER § 3523, in this area of law.

Unlike the sources of jurisdiction conferred by 28 

U.S.C. § 1367,

3 ancillary enforcement jurisdiction focuses on 

3 Passed in 1990, see Judicial Improvements Act of 1990, Pub. 

L. No. 101-650, 104 Stat. 5089, § 1367 codified the common 

law doctrines of pendent claim, ancillary, and pendent party 

jurisdiction. Pendent claim jurisdiction refers to a federal 

court’s power to adjudicate non-federal claims asserted by the 

plaintiff against the original defendant—over which the court 

would not have jurisdiction if brought independently—when 

those claims derive from a common nucleus of operative fact 

as the federal claim. See United Mine Workers of Am. v. Gibbs, 

383 U.S. 715, 75 (1966). Ancillary jurisdiction refers to a 

court’s power to adjudicate a claim asserted by a party other 

than the plaintiff (usually the defendant)—over which the court 

would not have jurisdiction if brought independently—when 

the second claim shares such a close logical connection with 

the original claim that it may be considered part of the same 

“transaction.” See Moore v. N.Y. Cotton Exch., 270 U.S. 593, 

609–10 (1926). Finally, pendent party jurisdiction refers to a 

court’s power to adjudicate non-federal claims asserted by a 

plaintiff against a party other than the original defendant. 

When the underlying claim over which the court had 

jurisdiction is based on diversity, the additional party must be 

diverse; when the underlying claim over which the court had 

jurisdiction is based on federal question jurisdiction, the 

additional party need not be diverse. See, e.g., Finley v. United 

States, 490 U.S. 545, 549–52, 555 (1989); Exxon Mobil Corp. 

v. Allapattah Servs., Inc., 545 U.S. 546, 558–67 (2005). These 
8

“the power [of federal courts] to enforce their judgments and 

ensur[es] that they are not dependent on state courts to enforce 

their decrees.” Nat’l City Mortg. Co. v. Stephen, 647 F.3d 78, 

85 (3d Cir. 2011). It stems from the proposition that “[a] 

district court acquires jurisdiction over a case or controversy in 

its entirety and, as an incident to the disposition of a dispute 

properly before it, may exercise jurisdiction to decide other 

matters raised by the case over which it would not have 

jurisdiction were they independently presented.” Id. (quoting 

Sandlin v. Corp. Interiors, Inc., 972 F.2d 1212, 1216 (10th Cir. 

1992)). Put differently, ancillary enforcement jurisdiction 

exists “to enable a court to function successfully, that is, to 

manage its proceedings, vindicate its authority, and effectuate 

its decrees.” Kokkonen v. Guardian Life Ins. Co. of Am., 511 

U.S. 375, 380 (1994). This proposition has been applied 

consistently for over 200 years. See, e.g., United States v. 

Hudson, 11 U.S. (7 Cranch) 32, 34 (1812) (recognizing the 

contempt power as an “implied power” necessary to a court’s 

three sources of jurisdiction involve the power of federal courts 

to hear separate claims. 

Unlike those sources, ancillary enforcement jurisdiction relates 

to the power of a federal court to exercise jurisdiction over 

separate proceedings. Although not mentioned in § 1367, this 

common-law doctrine has survived the codification of 

supplemental jurisdiction and remains independent of the 

statute. See, e.g., Kokkonen v. Guardian Life Ins. Co. of Am., 

511 U.S. 375, 379 (1994); Peacock, 516 U.S. at 356; Nat’l City 

Mortg. Co. v. Stephen, 647 F.3d 78, 85 (3d Cir. 2011); Robb 

Evans & Assocs., LLV v. Holibaugh, 609 F.3d 359, 363 (4th 

Cir. 2010).
9

proper functioning); Bank of the United States v. Halstead, 23 

U.S. (10 Wheat.) 51, 53 (1825) (“The authority to carry into 

complete effect the judgments of the Courts, necessarily 

results, by implication, from the power to ordain and establish 

such Courts.”); Cooter & Gell v. Hartmarx Corp., 496 U.S. 

384, 395 (1990) (listing proceedings for costs and attorneys’

fees as collateral issues “that a federal court may consider after 

an action is no longer pending”).

Nor does ancillary enforcement jurisdiction end when a 

court renders a judgment on the merits or dismisses a case. As 

Chief Justice Marshall recognized: “[t]he jurisdiction of a 

[c]ourt is not exhausted by the rendition of its judgment, but

continues until that judgment shall be satisfied.” Wayman v. 

Southard, 23 U.S. (10 Wheat.) 1, 23 (1825); see also Riggs v. 

Johnson Cnty., 73 U.S. (6 Wall.) 166, 187 (1867) (“Process 

subsequent to judgment is as essential to jurisdiction as process 

antecedent to judgment, else the judicial power would be 

incomplete and entirely inadequate to the purposes for which 

it was conferred by the Constitution.”). “It is well established 

that a federal court may consider collateral issues after an 

action is no longer pending,” including “motions for costs or 

attorney’s fees.” Cooter & Gell, 496 U.S. at 395; see also 

White v. N.H. Dep’t of Emp. Sec., 455 U.S. 445, 451 n.13 

(1982) (explaining that, even “years after the entry of a 

judgment on the merits,” a federal court may award counsel 

fees); Nat’l City Mortg. Co., 647 F.3d at 85 (holding the 

District Court had ancillary jurisdiction after judgment was 

entered in order to give effect to the remedy it granted). 

These precedents lead us to conclude that the District 

Court had ancillary enforcement jurisdiction over the dispute 

between Thompson and Paddick. The Supreme Court has 

indicated that ancillary enforcement jurisdiction extends to 
10

attorney fee disputes. White, 455 U.S. at 447–48, 452, 454

(resolving a post-judgment motion for attorney’s fees under 42 

U.S.C. § 1988 more than four months after the parties settled 

the case and the district court approved a consent decree); 

Sprague v. Ticonic Nat’l Bank, 307 U.S. 161, 170 (1939)

(holding that because a petition for fees is “an independent 

proceeding supplemental to the original,” the suggestion “that 

it came after the end of the term at which the main decree was 

entered and [is] therefore too late” was unavailing). Numerous 

federal courts have recognized the same. See, e.g., K.C. ex rel. 

Erica C. v. Torlakson, 762 F.3d 963, 968 (9th Cir. 2014)

(“There is no debate that a federal court properly may exercise 

ancillary jurisdiction over attorney fee disputes collateral to the 

underlying litigation.” (internal quotation omitted)); In re 

Austrian & German Bank Holocaust Litig., 317 F.3d 91, 98 (2d 

Cir. 2003) (same); Zimmerman v. City of Austin, 969 F.3d 564, 

568 (5th Cir. 2020) (same); WRIGHT &MILLER § 3523.2 (“One 

of the best-established uses of ancillary jurisdiction is over 

proceedings concerning costs and attorney’s fees.”). As 

discussed, jurisdiction over attorney fee disputes continues 

after the resolution of the underlying case.

This Court has addressed the role of ancillary 

enforcement jurisdiction in the realm of legal fee disputes on 

several occasions, most importantly in Novinger v. E.I. DuPont 

de Nemours & Co., 809 F.2d 212 217–18 (3d Cir. 1987), and 

In re Community Bank of Northern Virginia Mortgage Lending 

Practices Litigation, 911 F.3d 666, 671–74 (3d Cir. 2018). In 

Novinger, we upheld the district court’s exercise of ancillary 

jurisdiction over a fee dispute between a client and the client’s 

former counsel following a settlement agreement in the client’s 

underlying case (but before the district court had approved the 

settlement and dismissed the action). Novinger, 809 F.2d at 
11

213, 217. Because the former counsel was attempting to obtain 

a portion of the client’s fund, the underlying case could not be 

fully resolved without a determination as to the fees. Federal 

courts, we noted, have a “vital interest” in resolving fee 

disputes in such a case “because they bear directly upon the 

ability of the court to dispose of cases before it in a fair 

manner.” Id. at 217. The district court’s ability to enforce and 

effectuate the settlement agreement, then, “necessarily 

includes the power to resolve disputes with respect to the 

payment of attorneys’ fees and expenses.” Id.

Thirty years later we circled back to a question left 

unresolved in Novinger: whether “ancillary jurisdiction 

extends to the resolution of a post settlement fee dispute

between two attorneys, only one of whom was attorney of 

record.” Id. at 218 n.4. We held ancillary jurisdiction did not 

exist. In re Cmty. Bank, 911 F.3d at 672. That was because the 

district court “ha[d] no control over the [settlement] funds” and 

“the fee-splitting dispute ha[d] no impact on the timing or 

substance of the litigants’ relief in the underlying case.” Id.

This case differs from In re Community Bank in 

meaningful ways. Most notably, both Paddick and Thompson 

were counsel-of-record to the Clients. Another significant 

difference is that the District Court here has control over the 

disputed funds. It first ordered Thompson to maintain “[t]he 

contested portion” in an “escrow account pending resolution of 

the motion,” Dist. Ct. Dkt. No. 321, at 2, and later ordered 

Thompson, “[a]s custodian of the escrow account,” to release 

the funds to Paddick, Dist. Ct. Dkt. No. 357, at 2. And because 

Thompson argued then (and now) that Paddick’s fees must 

come from the Clients’ portion of the settlement fund, the 

resolution of the fee dispute could have “impact[ed] . . . the 

timing or substance of the litigants’ relief.” In re Cmty. Bank, 
12

911 F.3d at 672. Had the District Court agreed with Thompson 

that any fees due to Paddick were to be collected from the 

Clients’ share, they would have received roughly $54,000 less. 

Such a reduction would have had a significant impact on the 

Clients’ relief.

Given the abundance of caselaw supporting the 

application of ancillary enforcement jurisdiction to attorney’s

fee disputes—even after disposition of the underlying case

where jurisdiction was not explicitly retained—we hold the 

District Court did not err in exercising such jurisdiction over 

this fee dispute that was raised for the first time after dismissal 

of the underlying case but was necessary to effectuate the 

Court’s judgment.

III

Having concluded the District Court properly exercised 

jurisdiction over the fee dispute, we turn to the merits of 

Thompson’s remaining arguments. The District Court 

correctly addressed each at length in its thorough and wellreasoned opinion. See Butt, 2018 WL 1991737, at *2–21. 

A

Thompson claims the District Court erred when it 

awarded Paddick fees because the doctrines of duress and 

unclean hands bar him from any recovery. We disagree.

1

Thompson’s duress argument is based on the notion that

the Clients signed contingency agreements with Paddick only 

after he approached them the night before their Third Circuit 

argument and threatened to not appear. According to 
13

Thompson, “perceiving the impending threat and danger to 

their appeal,” the Clients “were induced into retaining 

Paddick.” Butt Br. 33. These facts render the agreements void, 

Thompson claims. 

The District Court rejected this argument, finding the 

Clients failed to produce clear and convincing evidence of “a 

wrongful act or threat by [Paddick] that left the [Clients] no 

reasonable alternative.” Butt, 2018 WL 1991737, at *5 

(quoting Seal v. Riverside Fed. Sav. Bank, 825 F. Supp. 686, 

695 (E.D. Pa. 1993)). The Court pointed to evidence of a 

positive relationship between the Clients and Paddick after the 

Third Circuit argument. It also emphasized that the Clients did 

not exercise their rights to terminate their agreements with 

Paddick until over two years after signing them. Finally, after 

weighing conflicting testimony from the Clients and Paddick 

as to Paddick’s alleged threat to not appear for oral argument, 

the Court found “Paddick’s testimony on this point more 

credible than that which was offered by the Former Clients.” 

Id. at *6. Because these factual findings were not clearly 

erroneous, see Fields v. Speaker of Pa. House of Reps., 936 

F.3d 142, 149 (3d Cir. 2019), we agree with the District Court

that Thompson failed to establish duress by clear and 

convincing evidence. Cooper v. Oakes, 629 A.2d 944, 948 (Pa. 

Super. Ct. 1993) (“The proponent of avoiding the agreement 

then bears the burden of proving . . . duress by clear and 

convincing evidence.” (emphasis omitted)).

2

Even if the agreements were valid when entered, 

Thompson argues, Paddick is still barred from quantum meruit 

recovery under the doctrine of unclean hands. Thompson 

provides a laundry list of alleged missteps Paddick made at 
14

various stages of his representation of the Clients. See Butt Br. 

34–40. Considered together, Thompson asserts, Paddick’s 

failures bar recovery of fees. 

As the District Court aptly noted, “inadequacy in 

[Paddick’s] representation of the [Clients] goes to the amount 

of quantum meruit recovery.” Butt, 2018 WL 1991737, at *14 

(quoting Mulholland v. Kerns, 822 F. Supp. 1161, 1170 (E.D. 

Pa. 1993)). Without “convincing evidence that Paddick ha[d] 

committed illegal acts in his representation of the Former 

Clients,” Paddick was not barred from reasonable 

compensation for the value of his services. Id.

Paddick may not have provided the Clients flawless

representation. But his acts do not constitute unconscionable 

conduct such that recovery should be precluded. See, e.g., In re 

Est. of Pedrick, 482 A.2d 215, 222–23 (Pa. 1984). We agree 

with the District Court that any such shortcomings in 

performance go to the amount he deserves under the equitable 

doctrine of quantum meruit. Imperfect representation does not 

necessarily bar Paddick from recovery. 

B

Thompson’s fallback position is that even if Paddick is 

entitled to fees, they must be paid from the Clients’ share of 

the settlement fund. Under her contingency fee agreement with 

the Clients, Thompson “limited her liability as substituting 

counsel for any of Paddick’s actions or inactions.” Butt Br. 42

(emphasis omitted). Thompson cites the language in her 

agreements—coupled with the fact Paddick filed his motion 

against the Clients instead of Thompson—to show that 

Paddick’s fee cannot be taken from Thompson. 
15

In a separate order and opinion following a hearing, the 

District Court rejected Thompson’s argument, holding that the 

fees must come from Thompson’s $133,000. See Paddick v. 

Butt, 2018 WL 2359401 (E.D. Pa. May 24, 2018). “The 

consequence of what Thompson would like us to do,” the 

District Court wrote, “would leave her clients with just 

over . . . half (51%) of their settlement proceeds.” Id. at *5. 

Relying on a Massachusetts Supreme Court case as persuasive 

authority, the District Court held that Thompson’s request was 

“manifestly unjust,” id., because a client “should never be 

made to pay twice,” id. (quoting Malonis v. Harrington, 816 

N.E.2d 115, 123 (Mass. 2004)) (District Court’s emphasis).

4

For the reasons set forth in the District Court’s thorough 

opinion, we will affirm the Court’s order that Paddick’s fees 

must come from Thompson’s portion of the settlement fund.

C

Thompson’s final argument—that Magistrate Judge 

Strawbridge “abused his discretion in failing to recuse 

himself,” Butt Br. 46—also fails.

5 Thompson made many

accusations of partial behavior in her motion for recusal (and 

4 The District Court expressed a similar view during the 

hearing. See App. 748 (“It is inconceivable to me that any 

prudent lawyer would not expect that there’s a possibility of an 

attorney lien coming and if there’s an attorney lien coming 

[you must] calculate that [when negotiating your fee].”).

5 In May 2017, the parties consented to proceed before United 

States Magistrate Judge David Strawbridge. See 

28 U.S.C. § 636(c)(1). 
16

the accompanying affidavit and brief). On appeal, Thompson 

focuses on three examples of alleged bias by Magistrate Judge 

Strawbridge: (1) on a phone call with Thompson and counsel 

for one of the defendants, he “offered reasons why he was 

‘frustrated’ with Thompson”; (2) he “strongly suggested to 

Thompson that Paddick would recover [on Paddick’s lien] and 

it would come from her fee”; and (3) he “acted as former 

clients’ advocate throughout the [lien] hearing.” Butt Br. 46–

47.6 When considered together, Thompson concludes, 

Magistrate Judge Strawbridge’s “impartiality might 

reasonably be questioned” so recusal was required under 

28 U.S.C. § 455(a). Butt Br. 47. 

The District Court, relying heavily on the Supreme

Court’s decision in Liteky v. United States, 510 U.S. 540 

(1994), disagreed, holding that no “reasonable observer 

considering the totality of the circumstances would believe that 

the Court was acting based upon bias, prejudice, or any other 

improper motive.” Butt, 2018 WL 1991737, at *21. Our 

independent review of the record revealed no evidence of bias 

by Magistrate Judge Strawbridge. The negative comments he 

made reflected his views on the merits of Thompson’s 

arguments, not prohibited bias.

As to the first allegation—that the judge expressed 

frustration with Thompson—the District Court correctly noted: 

6 In her Reply Brief, Thompson claims the Court “acted as 

Paddick’s advocate against former clients.” Reply Br. 19. 

Regardless of whether Thompson believed the Court was 

serving the Clients’ or Paddick’s interests (or both), her 

common refrain is that the Court was acting against her

interests.
17

“judicial remarks during the course of a trial that are critical or 

disapproving of, or even hostile to, counsel . . . ordinarily do 

not support a bias or partiality challenge,” Liteky, 510 U.S. at 

555, and do not support such a challenge here. Thompson’s 

second allegation—that the Court suggested Paddick would 

recover his fee from Thompson—is likewise not grounds for 

recusal. “[O]pinions formed by the judge on the basis of facts 

introduced or events occurring in the course of the current 

proceedings, or of prior proceedings, do not constitute a basis 

for a bias or partiality motion.” Id. A remark as to the perceived 

strength of the case after a day of testimony would not, to a 

reasonable observer, “reflect[] a fixed or immovable view 

about the merits of Paddick’s request for a counsel fee.” Butt, 

2018 WL 1991737, at *20. Finally, Thompson’s claim that 

Judge Strawbridge acted as counsel against her when he 

questioned witnesses is equally unavailing. “A judge’s 

ordinary efforts at courtroom administration” are “immune” 

from a recusal challenge. Liteky, 510 U.S. at 556.

The District Court accurately described the governing 

law set forth in Liteky and correctly applied it here. The Court 

did not abuse its discretion when it denied Thompson’s recusal 

motion. See Edelstein v. Wilentz, 812 F.2d 128, 131 (3d Cir. 

1987).

* * *

For the reasons we have explained, the District Court 

had ancillary enforcement jurisdiction over the fee dispute 

between Paddick and Thompson. And because Thompson’s 

other claims lack merit, we will affirm the judgment of the 

District Court.