In a personal injury suit against Megabus with a highly unusual procedural history, a Philadelphia judge has voluntarily recused herself, but not without first taking to task the defense counsel for what she described as "outrageous" discovery conduct.

In a one-paragraph order that extended to three pages thanks to a lengthy footnote, Philadelphia Court of Common Pleas Judge Frederica A. Massiah-Jackson said Megabus Northeast’s motion for recusal was "baseless and brought to deflect attention from the outrageous misconduct of Megabus and their counsel." Although Massiah-Jackson technically denied Megabus’ motion that she recuse based on alleged favoritism toward plaintiff Candice Burks, the judge voluntarily recused herself to "avoid any prospective appearance of impropriety."