Supreme Court Issues Opinion Clarifying Judicial Recusal Standard

The Supreme Court issued an opinion in Commonwealth v. Rangamar today addressing how the Commonwealth’s judicial recusal statute applies in cases involving specialty courts. Sergio Rangamar was convicted after a bench trial of one count of assault and battery, one count of assault, and two counts of disturbing the peace. During the trial, one of the prosecution’s principal witnesses was participating in the Drug Court program, where she appeared regularly before the same judge in a non-adversarial setting. Rangamar raised two issues on appeal: (1) the judge should have been disqualified; and (2) the court should have conducted an in camera review of the witness’s confidential Drug Court records.

Under 1 CMC § 3308(a), recusal is required when a reasonable, fully informed person would question a judge’s impartiality. The Court explained that prior judicial exposure to parties or witnesses does not ordinarily require recusal because judges routinely encounter the same individuals in the course of their duties. However, the analysis may differ in bench trials—where the judge serves as the factfinder—and in cases involving specialty courts that require ongoing judicial supervision.

After reviewing the record, the Court concluded that disqualification was required in this case. Sustained supervisory interactions with a key witness outside the adversarial proceedings may create an appearance of partiality in a bench trial where credibility assessments are central to the outcome. The opinion emphasized that the holding is narrow and limited to the specific circumstances presented.

On the second issue, the Court rejected Rangamar’s request for disclosure of the witness’s Drug Court records. It held that the trial court was not required to conduct an in camera review of those confidential records because Rangamar did not make a sufficient showing that the records likely contained material evidence.

The full opinion is available on the Law Revision Commission website: https://cnmilaw.org/pdf/supreme/2026-MP-03.pdf.