Winkle v. Relay Administration Board

Summary

The Louisiana Supreme Court held that a judge’s potential financial interest in a class action does not require recusal under La. Code Civ. P. art. 151(A)(4) absent evidence that the interest would prevent fair and impartial proceedings. Because the judge’s potential interest amounted to approximately $13 in telephone charges over ten years, the court reversed the recusal order and remanded the case to the division to which it was originally allotted.

Holdings

1. A mere finding that a judge is interested in the cause or its outcome does not require recusal under La. Code Civ. P. art. 151(A)(4); the interest must be substantial enough that the judge would be unable to conduct fair and impartial proceedings.
2. Recusal was not mandated because the judge's potential interest was minimal and there was no evidence that the amount would affect her ability to conduct fair and impartial proceedings.

Questions Presented

1. Whether La. Code Civ. P. art. 151(A)(4) requires recusal merely because a judge has an interest in the cause or its outcome.
2. Whether a judge's potential interest consisting of approximately $13 in telephone charges, without evidence that the amount would impair impartiality, mandated recusal.

Disposition

reversed_and_remanded