In In re Moore, the Fourth Circuit denied a petition for a writ of mandamus, asking that the court direct Judge Conrad to recuse from presiding over petitioner’s criminal trial. The Fourth Circuit acknowledged that recusal might be required at a future point; however, it concluded that the extraordinary relief of mandamus was not warranted at this stage of the proceedings.

In Servotronics, Inc. v. Boeing Co.,the Fourth Circuit held that under 28 U.S.C. § 1782, which provides that a U.S. District Court may provide assistance in providing testimony for a proceeding before “a foreign or international tribunal,” that private arbitration in the United Kingdom between two companies in the United Kingdom would qualify as such a tribunal.