Opinion Ratings

Justice-Denied.org Comment: State v. Fields 🔗 was decided properly. In Fields, the judge reviewed evidence that had already been presented by the parties, which consisted of an audio recording of an earlier proceeding before the same judge, in the same case.

Justice-Denied.org Comment: State v. Jones 🔗 was not decided properly. Despite the MN Supreme Court’s recent decision in Duol, the MN Court of Appeals found yet another exception to the “bright-line” rule prohibiting independent judicial investigation.

Update: On January 21, 2026, the Minnesota Supreme Court granted review of Issue 1 (independent judicial investigation) in State v. Jones.

Justice-Denied.org Comment: State v. Duol 🔗 was decided properly. The MN Supreme Court carefully analyzed the issues, determined that Mr. Duol’s constitutional rights had been violated by the District Court judge’s independent investigation, and reversed. The case was remanded for a new evidentiary hearing before a different judge.

The MN Supreme Court stated: “We have recognized a “bright-line rule that judges may not engage in independent investigations of facts in evidence . . . .” Id. at 251; see also Lopez, 988 N.W.2d at 119 (reaffirming this principle). When a district court judge does so, they no longer act as a fair and impartial judge. We have never recognized an exception to this guardrail.“ State v. Duol (emphasis added)

Justice-Denied.org Comment: Stevenson v. Stevenson 🔗 was not decided properly. Despite the district court judge introducing his own extra-record facts after taking the matter under advisement, and despite a sworn declaration filed by one of the Plaintiffs eight days after the hearing, the MN Court of Appeals deemed the issue of independent judicial investigation forfeited, essentially condoning the violation of Appellants’ constitutional right to an impartial judge.

Justice-Denied.org Comment: The core issue of independent judicial investigation in State v. Oxendine 🔗 was decided properly. The judge’s independent investigation required reversal and the case was remanded for a new trial on the affected count(s). However, the case was remanded to the same judge. It seems to us as if the case should have been remanded to a different judge.

Justice-Denied.org Comment: The core issue of independent judicial investigation in State v. Bowlby 🔗 was decided properly. The judge’s independent investigation required reversal and the case was remanded. However, the case was remanded to the same judge because “neither party requested [the MN Court of Appeals] to do so.” It seems to us as if the case should have been remanded to a different judge whether or not a formal request was made.

Justice-Denied.org Comment: State v. Knopik 🔗was decided properly, although a much closer call than other decisions. The judge’s actions in this case were not deemed to qualify as an independent investigation.

Justice-Denied.org Comment: The core issue of independent judicial investigation in State v. Scudder was decided properly. The judge’s independent investigation required reversal and the case was remanded for a new restitution hearing. However, the case was remanded to the same judge. It seems to us as if the case should have been remanded to a different judge.

Although not specifically required by the MN Court of Appeals, it appears as if the District Court judge voluntarily recused herself following the appeal. (See 62-CR-19-5073, Doc. 63.) However, it also appears as if the judge continued to work on the case following her own recusal.

Justice-Denied.org Comment: State v. McCorquodale was decided properly. The judge’s use of extra-record facts that were incorporated into the district court’s findings of fact required automatic reversal and the case was remanded for a new trial before a different judge.

Justice-Denied.org Comment: State v. Leonida was not decided properly. Although we acknowledge that Mr. Leonida requested that the judge investigate, the judge was prohibited from doing so.

It is also important to note that Mr. Leonida’s request to review a prior Pre-Sentence Investigation (PSI) was made to a different judge, the State’s argument about this request was a new legal argument that had not been raised at the district court, had not been briefed, and was brought up for the first time during oral argument. Many of these facts were not mentioned in the opinion, but could only be gleaned from the oral argument recording. Despite these issues, the MN Court of Appeals did not deem the argument forfeited, as it would do several years later in Stevenson v. Stevenson, with Judge Tracy M. Smith serving on both panels.

Justice-Denied.org Comment: State v. Leckner was decided properly. The judge’s independent investigation required reversal and the case was remanded for sentencing before a different judge.

Justice-Denied.org Comment: The core issue of independent judicial investigation in In re Welfare of A.J.G. was decided properly. The judge’s independent investigation required reversal and the case was remanded for a new trial. However, the case was remanded to the same judge. It seems to us as if the case should have been remanded to a different judge.

Justice-Denied.org Comment: The core issue of independent judicial investigation in State v. Weidenbach was decided properly. The judge’s independent investigation required reversal, but the case was remanded to the same judge. It seems to us as if the case should have been remanded to a different judge.

Justice-Denied.org Comment: Wakasugi v. 3M was decided properly. The presence of disputed material facts precluded summary judgment, requiring reversal. Judge Randall Slieter was the presiding judge in this case.

Justice-Denied.org Comment: Stevenson v. Stevenson 🔗 was not decided properly. Despite the presence of many material facts in dispute, the MN Court of Appeals affirmed the district court ruling, directly contradicting its prior ruling in Progressive Insurance v. Abel and its subsequent ruling in Wakasugi v. 3M, which held that a genuine issue of material fact precluded summary judgment. Judge Randall Slieter was the Presiding Judge in all three cases.

Justice-Denied.org Comment: Progressive Insurance v. Abel was decided properly. The presence of disputed material facts precluded summary judgment, requiring reversal. Judge Randall Slieter was the presiding judge in this case.

Also notable in this case was the prohibition against the use of selected facts, citing Skarsten v. Dairyland Ins. Co. (C1-85-1533):

In Skarsten, we reversed summary judgment for the insurer based on the resident-relative provision and cautioned “a court must not rely on selected facts in order to justify a conclusion.” 381 N.W.2d at 19. Here, the district court’s summary-judgment decision rested on “selected facts” because it ignored relevant evidence favorable to appellants’ position, drew inferences unfavorable to appellants, and failed to view the record evidence in a light favorable to appellants.