Question juridique clé
Whether the cantonal judges had to recuse themselves for apparent bias under the Federal Constitution and ECHR.
Solution extraite
No objective circumstances established an appearance of bias; prior criticism of filings and a statutory criminal report did not require recusal of all judges.
Motifs extraits
The court held that the president’s letter about abusive filings did not show hostility toward the appellant, and procedural or substantive errors do not themselves create an appearance of bias. A judge’s statutory duty to report suspected offences likewise does not make the bench generally impartiality-tainted.