Question juridique clé
Whether the appeal was admissible, including the standing of the appellants
Solution extraite
The criminal appeal was admissible only to the extent that the complaining party had participated below; the wife lacked standing because she had not participated in the cantonal proceedings.
Motifs extraits
Separate incidental decisions on recusal are challengeable by criminal appeal; however, standing under the federal rules requires prior participation in the lower proceedings.