Layton v. Layton and Howard

Summary

The Court dismissed Mother’s appeal from the dismissal of Grandfather’s guardianship petition because Mother lacked standing to appeal when Grandfather, the petitioner, did not appeal. The Court affirmed the denial of Mother’s recusal motion, holding that the judge’s adverse rulings, participation in a continuing legal education panel with a prior witness, and Mother’s speculation about improper communications did not establish subjective or objective bias. The Court consolidated the appeals because the recusal ruling was reviewable as a subsidiary ruling and addressed its merits.