State v. Duol, 2025 Minn. LEXIS 470 (Minn. 2025)

The Supreme Court of Minnesota ruled that due process requires an impartial judge and offered the following language in support.

“We conclude by emphasizing that the Minnesota Constitution’s guarantee of due process includes the right to an impartial judge. Minn. Const. art. 1 § 7. We therefore clarify that our holding in this case—that due process requires a bright-line rule prohibiting independent judicial investigations into facts outside the record and that such an investigation constitutes a structural error—is based separately and independently on the Minnesota Constitution. See Michigan v. Long, 463 U.S. 1032, 1041, 103 S. Ct. 3469, 77 L. Ed. 2d 1201 (1983).”