State of Minnesota v. Buay David Duol
Syllabus
A district court judge's deliberate independent investigation and consideration of extra-record facts in denying a petition for postconviction relief violates the petitioner's constitutional right to an impartial judge. Such a violation is a structural error requiring automatic reversal under the Due Process Clause of the Minnesota Constitution. Reversed in part and remanded.
Opinion Excerpt
STATE OF MINNESOTA IN SUPREME COURT A22-0748 A24-1754 Hennepin County Moore, III, J. State of Minnesota, Respondent, vs. Filed: September 3, 2025