State of Minnesota v. Buay David Duol

Summary

The court held that the postconviction judge violated Duol’s due process right to an impartial judge by independently investigating and relying on facts outside the evidentiary record when assessing a witness’s credibility. The violation was structural, so harmless-error analysis did not apply, and the court reversed in part and remanded for a new evidentiary hearing before an impartial judge. The court did not reach the merits of Duol’s newly discovered evidence claim or his statutory and judicial-conduct recusal arguments.