Key legal question
Whether the judge’s prior participation in separate criminal proceedings required recusal in the civil case.
Extracted holding
No. A judge is not disqualified merely because he sat in two different cases involving the same party; objective circumstances showing an appearance of bias were absent.
Extracted reasoning
The earlier criminal decisions concerned another matter, not the same case. The appellant’s subjective distrust of the cantonal justice system could not replace objective facts establishing apparent partiality.