North Am. Title Co. v. Superior Court

Summary

The court held that a party's verified statement seeking judicial disqualification for alleged bias or prejudice must be filed at the earliest practicable opportunity after discovery of the supporting facts. The statutory nonwaiver provision applies to express waivers of a judge's self-disqualification, not to a party's untimely failure to seek disqualification, which constitutes forfeiture. The court reversed and remanded for the Court of Appeal to decide whether North American Title's statement was timely.