A caption containing a questionable assumption, under a photograph of Donald Trump, at a NYT article by Michael Barbaro and Megan Twohey titled "A Biased Judge? Donald Trump Has Claimed It Before."
I guess the accuracy of the statement depends on what the meaning of "be" is.
How could reporters possibly know the level of hostility people in court cases feel toward the judge? There are plenty of reasons to be hostile toward the judge in your case. This person holds government power directly over you. He or she orders you around, constrains your speech, and may take your money or your liberty or deny you a remedy for your injuries — all for reasons that will be presented as punctiliously neutral and rational while you're deprived of the knowledge of what's really going on inside their head.
But maybe what the NYT means by "be hostile" is not feel hostile, but express hostility. Yes, of course, most litigants don't express hostility toward the judge in any way that the judge is likely to hear. Behaving strategically, you wouldn't normally choose to let the judge know you don't like him. And that's one more reason to be afraid of judges: They don't hear honest opinion about what people think of them. They're treated with extreme, even servile respect by most of the people around them.
This convention — borne of fear and need — makes deviation from the norm all the more striking.
That's Donald Trump. Saying things you feel but don't dare say. Oh, no, not you, specifically, but those other people out there in the hinterlands. They must be people who are unlike most people... because if most people feel that Donald Trump is saying what they think but are afraid to say, then, in a democracy, Donald Trump would win.
Most people don't say they're hostile toward the judge in their case, and most people don't say Donald Trump expresses what they only think and don't say. But Donald Trump is winning....
By the way, I love this line from the NYT article: "He does this despite his close ties to a federal judge, Maryanne Trump Barry, his sister." Wow! That's what you call the Butterfield Fallacy (presenting a cause-and-effect relationship as a paradox). If your sister were a long-time federal judge, you'd be less intimidated by judges, less respectful, more likely to see judges as real people and not neutral dispensers of law, more likely to take it personally, to get angry, and to express your antagonism.