A federal judge ordered Colorado’s former judicial discipline director on Tuesday to explain why she should not sanction him a second time for filing documents for improper purposes, such as harassment or delay.

U.S. District Court Senior Judge Kathryn H. Vratil is already scheduled to hear arguments and evidence on Thursday about potential misrepresentations made by Christopher S.P. Gregory, the former executive director of the Colorado Commission on Judicial Discipline, who is suing the state Supreme Court and related entities. But on March 24, Vratil issued another order raising the possibility that additional consequences are warranted from Gregory’s latest filings.

“Plaintiff’s assertions that the undersigned’s rulings demonstrate personal bias against him are highly speculative and flat-out wrong, if not sanctionable,” she wrote.

Vratil, of Kansas, was assigned to Gregory’s lawsuit last month under the provision of law allowing the chief judge of the U.S. Court of Appeals for the 10th Circuit to enlist an out-of-state judge when it would be “in the public interest.” Four of Colorado’s U.S. District Court judges recused or otherwise declined to handle Gregory’s case, after which Chief Judge Jerome A. Holmes of the 10th Circuit designated Vratil to preside.

On March 24, Gregory filed a motion seeking Vratil’s disqualification from his case. Quoting from emails his attorney sent to the defendants’ counsel at the Colorado Attorney General’s Office, Gregory indicated he was “under the impression” that Colorado’s chief district judge was the one who assigned Vratil to the case. Only recently did Gregory learn that Holmes made the assignment.

“This is a misrepresentation/omission of material facts on the part of the court and Judge Vratil specifically,” wrote attorney Ingrid DeFranco on behalf of Gregory. “We also believe that the judge should not conduct further proceedings until this issue has been decided.”

The attorney general’s office replied that it saw no reason why Vratil should recuse from the case.

The motion to disqualify Vratil followed multiple attempts by Gregory to demonstrate that the judges who have come into contact with his case engaged in nefarious conduct.

After the originally assigned judge recused herself, Gregory’s lawsuit landed on the desk of Chief Judge Daniel D. Domenico. Gregory filed a misconduct complaint against Domenico and asked him to recuse himself because of his connections to the defendants. Holmes dismissed the complaint in his role as chief circuit judge, after which Gregory filed a misconduct complaint against Holmes.

Domenico wound up recusing himself anyway. After the case was reassigned briefly to two other Colorado judges, Holmes enlisted Vratil to preside.

Vratil quickly set a hearing for March 26, at which she would address, among other topics, potential sanctions on Gregory for claiming to the court that the state defendants had failed to defend against his lawsuit to date.

“Specifically, plaintiff should address his representation that defendants had not ‘otherwise defended’ this action,” she wrote, “when as of February 18, 2026, counsel had entered appearances for defendants, filed motions to extend their time to answer or otherwise respond, and actively engaged with plaintiff on issues such as judicial recusal, confidentiality of filings, filing restrictions, deadlines and recusal of counsel.”

Days later, Gregory sought to eject her from the case.

Despite Gregory’s request that his lawsuit “should be assigned to a judge from outside the 10th Circuit through a conflict-free process, Chief Judge Holmes interfered to personally and directly assign the cases to Judge Vratil,” Gregory alleged in his recusal motion. “Chief Judge Holmes’s February 27, 2026, assignment order and all subsequent orders entered by Judge Vratil in this case must be vacated.”

In her latest order, raising the possibility of another round of sanctions, Vratil disclosed that Gregory has since filed a misconduct complaint against her. She also indicated on the docket that other judges who have interacted with Gregory’s case, beyond herself and Holmes, are now the subject of misconduct complaints.

“With no evidence, plaintiff baldly asserts that the undersigned was involved in concealing the manner in which this case was reassigned to her,” Vratil wrote. “Here, a reasonable person, with knowledge of all the circumstances of the reassignment, would entertain no suspicion that it was anything but an ordinary intra-Circuit assignment. Chief Judge Holmes and the undersigned did not communicate — directly or indirectly — about the reassignment of plaintiff’s cases, how she would manage them or what outcome he desired.”

She added that a judge’s rulings against a litigant rarely provide grounds for recusal, and that Gregory had not identified any of her opinions that allegedly demonstrated bias against him. Further, Gregory’s complaint of misconduct against her did not trigger an obligation to recuse.

“Plaintiff cannot manufacture personal bias or prejudice by filing a complaint against the undersigned. To hold otherwise would allow a party to disqualify one judge after another until the party is satisfied with the assigned judge,” Vratil wrote.

She gave Gregory until April 3 to explain why she should not sanction him for violating the rule against court filings that demonstrate an “improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the costs of litigation.“

Separately, U.S. Magistrate Judge Gwynne E. Birzer of Kansas, who was assigned to assist Vratil with Gregory’s lawsuit, issued her own order on Tuesday declining to recuse. In Birzer’s case, then-Chief Judge Philip A. Brimmer of Colorado enlisted her with the consent of Kansas’s chief judge. Gregory has also filed a misconduct complaint against Birzer.

“No reasonable person with knowledge of all the relevant facts would doubt the undersigned’s impartiality,” she wrote.

Gregory’s lawsuit seeks his reinstatement as the judicial discipline commission’s director and the removal of those appointed to the discipline, judicial performance, and judicial nominating roles. He is also the plaintiff in a related lawsuit that is sealed from public view.

The case is Gregory v. The Colorado Judicial Discipline Rulemaking Committee et al.