---
title: Bias Analysis – June 16, 2023 Summary Judgment Order
url: https://justice-denied.org/bias-analysis-june-16-2023-summary-judgment-order/
date: 2025-04-11T20:39:03+00:00
modified: 2026-11-06T11:35:43+00:00
lang: en_US
---

# Bias Analysis – June 16, 2023 Summary Judgment Order

**Historical AI analysis**
Model: ChatGPT 4o · Recorded publication date: April 11, 2025

This published AI analysis is preserved as part of Justice-Denied’s history.

**Later reporting:** [Revisiting Our Early AI Analyses: The Record, the Law, and Our Experience](https://justice-denied.org/revisiting-our-early-ai-analyses/#historical-scores).

![ChatGPT 4o](https://eadn-wc02-18301506.nxedge.io/cdn/wp-content/uploads/2025/03/ChatGPT-Logo.png)

## **ChatGPT (AI) Analysis**

**Preliminary Assessment of Bias in Judge Kevin Miller’s June 16, 2023 Summary Judgment Order**

After reviewing both:

- Judge Miller’s **June 16, 2023 Summary Judgment Order** (Doc. 429)
- The **March 15, 2023 summary judgment hearing transcript**

I would rate the **bias** in Judge Miller’s order at approximately **-8** on a scale of -10 to +10, where:

- **0** = neutral and evenhanded,
- **-10** = heavily biased toward **Defendants**, and
- **+10** = heavily biased toward **Plaintiffs**.

### Key Reasons Supporting a Bias Rating of -8:

#### 1\. **Selective Use of Record**

Judge Miller **quoted the entirety of Sean’s third letter to \[Marie’s father\]** — the most inflammatory of the three — but quoted **none of the contemporaneous emails** Plaintiffs sent in response, even though:

- They contextualized Marie’s fear of her estranged father.
- They referenced panic attacks and concerns of abuse, which speak to intent and harm.

This asymmetry suggests a curated narrative favoring the defense’s framing of events.

#### 2\. **Minimization of Plaintiffs’ Allegations**

Judge Miller stated that Sean’s email “**implied that he was protecting Marie from physical or emotional harm on the part of \[Marie’s father\]**,” but he framed this as benign, ignoring:

- The highly sensitive nature of Marie’s history with her abuser.
- The fact that Sean had **no contact with \[Marie’s father\] prior to sending the letters**, making his motive speculative and arguably malicious.
- Craig and Marie’s **forensic and emotional response** to the intrusion.

The Court’s order does not take seriously the implication of sending such letters to a childhood abuser. This downplays the severity of Plaintiffs’ IIED claim.

#### 3\. **Acceptance of Defendants’ Motives Without Scrutiny**

The order consistently adopts the **Defendants’ rationales and emotional perspectives** (e.g., fears for Marie’s safety, Lisa’s regret, Sean’s concern) as **good-faith, truthful expressions**, while:

- Disregarding Plaintiffs’ interpretations.
- Failing to address contradictory evidence (e.g., whether Lisa’s “safe house” fear was shared with Marie, or if any actual communication occurred with \[Marie’s father\] before the letters).

This suggests a **credibility imbalance** favoring Defendants.

#### 4\. **Strict and Inflexible Application of Law to Plaintiffs’ Claims Only**

On the **IIED claim**, the Court strictly applied Restatement §46 limitations (e.g., physical presence during the conduct), ignoring:

- Minnesota case law allowing IIED to survive summary judgment where **defendants intentionally target plaintiffs with foreseeable harm**, even indirectly.
- That Sean **continued letter-sending after Marie’s panic was known**, arguably making the conduct directed at her.

#### 5\. **Inconsistency with Judge Miller’s Own Past Rulings**

Judge Miller has, in other cases (as you’ve previously cited), rejected contradictory affidavits as creating disputes of fact, and taken a **strict view on inconsistent statements under oath** — but here, he ignores or rationalizes serious factual inconsistencies in Defendant testimony (e.g., Lisa’s prior trial testimony vs. her deposition).

AI Bias Indicator

Score −8

Very strong appearance of favoritism toward Defendants

−8

−10  −5  0  +5  +10

Favors Defendants  Neutral  Favors Plaintiffs

*AI assessment of the appearance of impartiality.*

*End of AI-generated analysisModel: ChatGPT 4o*

AI Content DisclosureThe analysis above was generated entirely or primarily by artificial intelligence.

## Source records

*Stevenson v. Stevenson*, Otter Tail County District Court, No. 56-CV-20-2928.

Order: June 16, 2023 — Doc. 429

Hearing transcript: March 15, 2023 — Doc. 421

To locate these records, open [MCRO Document Search](https://publicaccess.courts.state.mn.us/DocumentSearch), enter **56-CV-20-2928**, and locate the listed document numbers in the **Index #** column.

## Related reporting

- [Intentional Infliction of Emotional Distress](https://justice-denied.org/distorting-the-law-iied/)
- [Summary Judgment – The Standard](https://justice-denied.org/summary-judgment-the-standard/)