A Trump image on Judge Emil Bove III’s iPhone — showing the bloodied candidate after the Butler, Pennsylvania, assassination attempt — unsettled colleagues on the Third Circuit soon after he joined in September.
The concern centers on whether Bove, 45, can separate his judicial role from his past as Trump’s personal lawyer, including his defense of the president in the 2024 Manhattan hush-money trial.
Three people familiar with the photo said it caused discomfort on the 14-seat federal appeals court covering Pennsylvania, New Jersey and Delaware, where Bove is still acclimating.
Colleagues described a mixed early record: his rulings have broadly aligned with White House positions on immigration and diversity, but he has not yet faced a case directly involving Trump’s personal interests.
The episode reflects a wider strain on the judiciary as Trump appointees now make up about one-third of federal appellate judges and have largely backed his agenda.