Can a federal judge be found to have bias or prejudice in a sentencing hearing?

or prejudice concerning a party, or personal knowledge of disputed evidentiary facts concerning the proceeding," id. 455(b)(1). Section 455(a) is "commonly limited to those circumstances in which the alleged partiality stems from an extrajudicial source." United States v. Carlton, 534 F.3d 97, 100 (2d Cir. 2008) (alteration and internal quotation marks omitted). Opinions held by judges as a result of what they learned in a different case involving the same defendant and the same set of facts are "not ordinarily a basis for recusal." Id.

Here, defendants have pointed to no facts that would have warranted recusal. Their attempt to locate personal bias in the judge's (1) efforts to control defense counsel's duplicative cross-examination, (2) manner towards defense counsel, and (3) adverse evidentiary rulings is unconvincing. See Litkey v. United States, 510 U.S. 540, 556 (1994) (rejecting bias claim based on districtjudge's questioning of certain witnesses, alleged "anti-defendant tone," and limitations on testimony regarding defendants' state of mind (internal quotation marks omitted)). Moreover, the district judge's knowledge and opinions based on facts presented in related civil cases did not compel her recusal. See United States v. Carlton, 534 F.3d at 100.

In sum, we reject defendants' various challenges to their convictions as uniformly meritless.

6. Sentencing Challenges

a. Procedural Error

Defendants assert that the district court committed procedural error by

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