{"id":16771,"date":"2012-03-25T17:18:05","date_gmt":"2012-03-25T22:18:05","guid":{"rendered":"http:\/\/law.marquette.edu\/facultyblog\/?p=16771"},"modified":"2012-03-25T19:15:54","modified_gmt":"2012-03-26T00:15:54","slug":"signing-a-recall-petition-does-not-require-judicial-recusal","status":"publish","type":"post","link":"https:\/\/law.marquette.edu\/facultyblog\/2012\/03\/signing-a-recall-petition-does-not-require-judicial-recusal\/","title":{"rendered":"Signing a Recall Petition Does Not Require Judicial Recusal"},"content":{"rendered":"

\"\"<\/a>We live in interesting times.\u00a0 A segment of the general public is quick to forgive the killing of two young men in Slinger, Wisconsin and Sanford, Florida as the unavoidable consequence of the exercise of a constitutional right.\u00a0 Yet at the same time, state court judges\u00a0who have exercised their constitutional right of self-governance by signing a recall petition are being publicly called out by both special interest groups and the media, as if by signing the petition they have transgressed some moral boundary.\u00a0 These are interesting times, indeed.<\/p>\n

The signing of a recall petition is a right guaranteed by Article XIII of the Wisconsin Constitution.\u00a0 It is a procedure whereby any voter can request that the continuation in office of an elected official in the State of Wisconsin should be put to the vote of the full electorate.\u00a0 If a sufficient number of voters sign the petition, a recall election is held.\u00a0 A recall can only succeed in removing the officeholder if both a sufficient number of recall signatures are filed and a majority of the electorate votes in favor of removal.\u00a0 The Recall is democratic self-governance in its purest form, and along with the Initiative and the Referendum it is one of the three structural vehicles <\/a>by which Progressive Era voters sought to bypass the influence that special interests hold on elected bodies.<\/p>\n

The Wisconsin GOP has filed an official complaint <\/a>against Dane County Circuit Court Judge David Flanagan with the Judicial Commission on the grounds that the judge\u00a0should have recused himself in a case challenging the constitutionality of the Wisconsin Voter ID law.\u00a0\u00a0Must judges who have signed a recall petition subsequently recuse themselves from sitting on any case in which the Governor, or Republican legislators, or the Republican Party of Wisconsin asserts that the signing of the petition evidences a bias against them?\u00a0 The answer is \u201cno.\u201d\u00a0 There is no explicit provision that prohibits judges from signing a recall petition or that mandates that they recuse themselves from any politically charged case if they have done so.<\/p>\n

A judge\u2019s disqualification is required by law under the circumstance set forth in Wis. Stat. 757.19<\/a>, which generally lists instances in which a judge has a personal or financial connection to the case before the court.\u00a0However, one section of the statute, Wis. Stat. 757.19(2)(g), also requires disqualification \u201c[w]hen a judge determines that, for any reason, he or she cannot, or it appears he or she cannot, act in an impartial manner.\u201d\u00a0 This particular ground of mandatory disqualification is broad, however the Wisconsin Supreme Court has made it clear that the determination of whether the general provision of this subsection applies is to be left solely to the subjective determination of the judge.\u00a0 Donohoo v. Action Wisconsin, Inc<\/a><\/em>., 754 N.W.2d 480 (Wis. 2008).<\/p>\n

In the Donohoo<\/em> case, Justice Butler, while still a Circuit Court judge, had appeared at a fundraiser benefitting a gay rights organization and had accepted the endorsement of an attorney who worked for the organization.\u00a0 The Wisconsin Supreme Court ruled that then-Judge Butler could decide that he was capable of being impartial in a subsequent case involving gay rights, and that he was not required to disqualify himself.\u00a0 The Court made it clear that the majority agreed with the Judicial Commission\u2019s dismissal of a complaint arising out of the same facts:\u00a0 \u201cAs to Donohoo’s claim that Justice Butler acted improperly in attending the fund raiser, the Judicial Commission noted that \u2018[j]udges and candidates for judicial office can announce their views on political and legal issues as long as they are not pledges or promises to decide cases in a certain way.\u2019\u201d\u00a0 Therefore, the relevant precedent in Wisconsin leads to the conclusion that the mandatory disqualification rule would not apply to the signing of a recall petition, unless the judge who signed the petition doubted their ability to decide the case before them in an impartial manner.<\/p>\n

Because the disqualification grounds of Wis. Stat. 757.19 would not mandate the disqualification of Judge Flanagan in the Voter ID case, so long as he subjectively believed that he could continue on the case in an impartial manner, the question next turns to whether the Code of Judicial Conduct<\/a>, as reflected in the Rules of the Wisconsin Supreme Court, is somehow violated when a state judge signs a recall petition.\u00a0 Once again, the answer is \u201cno.\u201d\u00a0 There is no provision of the Code of Judicial Conduct that prohibits a sitting judge from signing a recall petition.<\/p>\n

For example, SCR 60.04(4) states that a judge should recuse herself when the facts and circumstances reveal a personal bias against a party or a lawyer involved in the case before her, an economic interest in the case before her, or where the judge has previously made a public statement on the merits of the legal issue involved in the case before her.\u00a0 None of these grounds apply to Judge Flanagan\u2019s handling of the Voter ID case.\u00a0 Governor Walker is not a real party of interest in the Voter ID case.\u00a0 The Governor is named as a defendant in his official capacity as the highest Executive Branch official charged with enforcing an allegedly unconstitutional law.\u00a0 None of Scott Walker\u2019s personal actions are at issue in the case and he faces no personal liability.<\/p>\n

Naming a government official as a defendant in their official capacity is a common practice.\u00a0 It does not make Judge Flanagan\u2019s personal opinion of Governor Walker relevant to the Voter ID case any more than Justice Scalia\u2019s personal opinion of President Obama is relevant to the case challenging the constitutionality of the Affordable Care Act (one of the lawsuits challenging the Act named President Obama as a defendant).\u00a0 Constitutional Law textbooks are filled with cases with names like Perry v. (Arnold) Schwarzenegger<\/em>, which challenged California\u2019s law prohibiting same sex marriage.\u00a0 Even though Governor Schwarzenegger publicly opposed the law being challenged by the plaintiffs, and he joined the plaintiffs in calling for the law to be struck down, the lawsuit that the plaintiffs filed still names him as a defendant in his official capacity as Governor.\u00a0 SCR 60.04(4) does not apply.<\/p>\n

Another potentially relevant rule is SCR 60.06, which is directed at \u201cinappropriate political activity\u201d by sitting judges and candidates for the judiciary.\u00a0 For example, SCR 60.06(2) prohibits judges from participating in the activities of a political party or a political candidate, or from endorsing the candidates of a political party.\u00a0 However, the plain language of this rule does not include the signing of a recall petition among the identified instances of \u201cinappropriate political activity.\u201d<\/p>\n

Moreover, the nature of the political activity identified as prohibited suggests that the Rule is focused on public actions by judges that would undermine the public\u2019s perception of the judiciary as a non-partisan institution.\u00a0 Many of the rule\u2019s provisions specify the prohibition of public endorsements and publicly expressed opinions, as distinguished from privately expressed opinions.\u00a0 Think of a judge who appears in a television ad for another political candidate, while wearing judicial robes and being identified as a judge.<\/p>\n

In contrast, the signing of a recall petition is not an action that is publicized by the judge, and the petition itself does not identify the signer as a member of the judiciary.\u00a0 It is true that the recall petition is an official document that is subject to public review.\u00a0 However, it is the supporters of Governor Walker who chose to turn the signing of the petition into a public act and to identify the signer as a member of the judiciary.\u00a0 None of the judges who signed a petition publicized the act or their judicial position.<\/p>\n

Note that the rules do not prohibit all political activity, only \u201cinappropriate\u201d political activity.\u00a0 The comment to SCR 60.06(2)(e) states the following:<\/p>\n

Although the rule contemplates the continuance of nonpartisanship on the part of Wisconsin judges and those seeking judicial office, judges are not expected to lead lives of seclusion. As members of the public and as public officeholders, judges may attend public events, even those sponsored by political parties or candidates, so long as the attendance does not constitute the kind of partisan activity prohibited by this rule. The judge, judicial candidate or judge-elect is responsible for so conducting herself or himself that her or his presence at the sponsored event is not made to appear as an endorsement or other prohibited political activity.<\/p><\/blockquote>\n

In other words, a judge may attend a partisan political event as a member of the public, without violating the Code of Judicial Conduct, so long as he or she does not call attention to themselves or to their official position.\u00a0 If a newspaper reporter recognized the judge at the event, and wrote a story publicizing the judge\u2019s attendance, that would not transform the judge\u2019s attendance at the event into a violation of the Rule.\u00a0 This comment further illustrates that SCR 60.06(2) is primarily focused towards political conduct that is intended for public consumption.<\/p>\n

Could the literal language of SCR 60.06(2) nonetheless be interpreted to reach the signing of a recall petition?\u00a0 Yes, it could, if one takes the view that the words of any statute have the quality of Play-Doh, and are susceptible to being formed into whatever shape one desires.\u00a0 This seems to be the position of Rick Esenberg, who has argued in a blog post\u00a0<\/a>that the words of SCR 60.06(2) could<\/em> be construed to apply to the signing of a recall petition without managing to articulate a reason why<\/em> we should choose to interpret the words in such a fashion.<\/p>\n

The last provision of the Judicial Code of Conduct that is arguably relevant to the signing of a recall petition is the general command contained in SCR 60.05(1)(a), wherein a judge is admonished to conduct their extra-judicial activity so as not to \u201ccast reasonable doubt on the judge’s capacity to act impartially as a judge.\u201d\u00a0 Should this very general language be interpreted so as to apply to the signing of a recall petition?<\/p>\n

Of course the language is capable of being applied to this situation \u2013 the language is so broad as to potentially apply to anything.\u00a0 When applying such broad language to a particular factual scenario, it is wise to reflect on the overall purpose of the broad prohibition.<\/p>\n

In my opinion, the issue of judicial recusal has become muddied as both political parties seek to use it for their advantage.\u00a0 If the judge has received something of value from a party or an attorney, then they should recuse themselves because they are presumed to be in that person\u2019s debt.\u00a0 This is the situation where Justice Gableman admittedly received free legal services from a law firm appearing before him.<\/p>\n

However, campaign contributions received by a judge from a party or their lawyer don\u2019t count as something of value unless the contributions are disproportionately large.\u00a0 See Caperton v. A.T. Massey Coal Company<\/a><\/em>, 556 U.S. 868 (2009).\u00a0\u00a0This is a tricky distinction to make, as campaign contributions can also create the perception that the judge is in the donor\u2019s debt, but it is a necessary distinction if we are going to elect judges.<\/p>\n

Finally, judges should not feel obligated to recuse themselves because of previously expressed political opinions that are unrelated to the case before the judge.\u00a0 In contrast to the situation where they receive something of value, here the judge is entitled to the presumption that they can decide the case in good faith.\u00a0 This latter situation\u00a0includes not only the signing of a recall petition but also attendance at conferences and events sponsored by liberal or conservative groups.<\/p>\n

There are two problems with interpreting the broad language of SCR 60.05(1)(a) to reach the signing of a recall petition.\u00a0 First, it would then be impossible to distinguish the signing of a recall petition from other actions that might be perceived as expressing a generalized political view, such as speaking at a Federalist Society event or accepting an award from the American Civil Liberties Union.\u00a0 In particular, the general language of SCR 60.05(1)(a) should not be construed to require mandatory recusal in situations where the expression of a general political opinion would not lead to mandatory disqualification under Wis. Stat. 757.19(2)(g).\u00a0 In the Donohoo<\/em> case, the Wisconsin Supreme Court interpreted both provisions in a parallel fashion.\u00a0 If the attendance at a fundraiser for a special interest group is not sufficient to create an automatic perception of bias requiring disqualification under the statute, then it should not require recusal under the Code of Judicial Conduct, and vice versa.<\/p>\n

Second, the signing of the recall petition is a constitutional right, and we should not interpret the broad language of SCR 60.05(1)(a) so as to force judges to forego their constitutional rights absent a compelling reason.\u00a0 \u00a0The need to identify some compelling state interest in policing a judge\u2019s expression of general political opinions is grounded in the recognition that all expressions of political opinion are the exercise of a constitutional right.\u00a0 The rights guaranteed under the First Amendment of the federal Constitution prevent a state from mandating the recusal of a sitting judge who declares \u201cI am a Democrat.\u201d\u00a0 Seifert v. Alexander<\/a><\/em>, 608 F.3d 974 (7th<\/sup> Cir. 2010).\u00a0 Similarly, the Wisconsin Constitution gives every voter who resides in this state the right to sign a recall petition.\u00a0 We ask our judges to comport themselves with integrity and to maintain an impartial attitude, but we do not demand that our state judges abandon all of their constitutional rights after being elected to the bench.\u00a0 The signing of a petition, without any attempt to draw attention to the act or to identify oneself as a judge, is not an effort to sway voters for partisan ends.\u00a0 There is therefore no compelling interest that would justify state regulation over this expression of opinion.\u00a0 This interpretation of the general requirement of impartiality in SCR 60.05(1)(a) is in accord with the general view of Justice Roggensack, who wrote for four members of the Wisconsin Supreme Court that recusal rules must be \u201cnarrowly tailored to meet a compelling interest.\u201d\u00a0 In the Matter of Amendment of the Code of Judicial Conduct\u2019s Rules on Recusal<\/a><\/em>, 2010 Wis. 73, Para. 11.<\/p>\n

Therefore, I conclude that the Code\u2019s regulation of extra-judicial political activity should not extend to prohibit the signing of recall petitions.\u00a0 Interpreting the recusal rules in ways that seek to police the expression of generalized ideology on the part of state court judges is a fool\u2019s game.\u00a0 We should not mandate the recusal of a judge unless their actions reveal a particular bias in relation to the actual parties, counsel or facts in the case before them.\u00a0 In a separate context, Rick Esenberg has noted, \u201c[h]aving a view on a legal or political issue is not the type of bias with which the state may concern itself.\u201d\u00a0 If You Speak Up, Must You Stand Down: Caperton and Its Limits<\/em>, 45 Wake Forest L. Rev. 1287, 1327 (2010).\u00a0 If this statement is true as a matter of general principle (and I believe that it is), then the belief that Scott Walker should be subject to a recall election has no relevance to the ability of a judge to be impartial in a case challenging the Voter ID law.<\/p>\n

My colleague Janine Geske, a former member of the Wisconsin Supreme Court, believes that Judge Flanagan and the others should have refrained <\/a>from signing the recall petitions so as to avoid any possible perception of partiality.\u00a0\u00a0I have the utmost respect for Janine Geske, and I would sleep better at night if she were still a member of the Court.\u00a0 I certainly cannot criticize her for encouraging judges to avoid activity that creates even the slightest perception of partisan activity.\u00a0 However, I do not understand her to contend that the Code of Judicial Conduct as currently written prohibits the signing of recall petitions by judges.\u00a0 Clearly, it does not.<\/p>\n

Judges should not be expected to conduct themselves so as to satisfy every\u00a0unrealistic expectation of an oversensitive minority.\u00a0 After joining the United States Supreme Court, Justice William Brennan was stung by criticism that his attendance at a legal conference might be perceived by some as endorsing the views of the conference organizers.\u00a0 As a result, he declined every subsequent speaking invitation that he received, no matter what the group.\u00a0 His biographers <\/a>Seth Stern and Stephen Wermiel note that this gregarious person maintained few professional friendships outside of his colleagues on the Supreme Court, and that having reached the pinnacle of the legal profession he became isolated from the practicing bar.\u00a0 Justice Brennan\u2019s strict refusal to attend any legal conferences may have been scrupulous, but it was sadly unnecessary.<\/p>\n

In the future, should we amend the recusal rules so that the rules explicitly mandate the recusal of judges who have expressed general political views that one of the parties finds objectionable?<\/p>\n

There are two schools of thought.\u00a0 One group argues that after Caperton<\/em> it would be useful to draft more explicit provisions setting forth the grounds for recusal in a wide variety of situations where the public may perceive the existence of bias.\u00a0 These commentators argue that a general \u201cimpartiality\u201d standard is insufficient to protect litigants from judicial bias, but that more focused rules would be more successful.\u00a0 Among the exponents of this view are Dmitry Bam, Making Appearances Matter: Recusal and the Appearance of Bias<\/em>, 2011 B.U.U. L. Rev. 943 and Tobin A. Sparling, \u00a0Keeping up Appearances: The Constitutionality of the Model Code of Judicial Conduct’s Prohibition of Extrajudicial Speech Creating the Appearance of Bias<\/em>, 19 Geo. J. Legal Ethics 441 (2006).<\/p>\n

A second school of thought argues that this approach is folly.\u00a0 Judges have the same opinions, beliefs and pre-dispositions as anyone else, and it is impossible to guarantee any litigant a judge for their case who has never previously expressed any political, social or economic point of view.\u00a0 Among the exponents of this view are Erwin Chemerinsky, Restrictions on the Speech of Judicial Candidates Are Unconstitutional<\/em>, 35 Ind. L. Rev. 735 (2002) and James Bopp, Jr. & Anita Woudenberg, An Announce Clause by Any Other Name: The Unconstitutionality of Disciplining Judges Who Fail to Disqualify Themselves for Exercising Their Freedom to Speak<\/em>, 55 Drake L. Rev. 723 (2007).<\/p>\n

I agree with the second school of thought.\u00a0 Parties have a reasonable expectation that their judge will not be biased towards their particular case; parties have no reasonable basis to expect that their judge is a blank slate who has never formed a political opinion on any issue nor adopted any religious or moral points of view.\u00a0 Rather than policing the expression of general ideology by members of the judiciary, the bar and the public should instead scrutinize the written opinions of judges to ensure that those opinions fairly discuss and resolve the arguments of counsel.\u00a0 The role of the judge is to put their ideology aside and to give the legal arguments of the parties a fair hearing, not to divest themselves of any vestiges of ideology in their personal life.<\/p>\n

I suspect that even the drafters of the complaint filed against Judge Flanagan with the Judicial Commission are aware of the tenuous nature of their legal argument.\u00a0 The Complaint filed by the Wisconsin GOP relies primarily upon a 2006 Court of Appeals decision named State v. Gudgeon<\/a> <\/em>that involves neither Section 757.19 nor SCR 60.05.\u00a0\u00a0Nowhere does the Complaint by the Wisconsin GOP discuss the 2008 Donohoo<\/em> opinion of the Wisconsin Supreme Court which is directly on point.\u00a0 Perhaps the Wisconsin GOP views their complaint as nothing more than a bargaining chip, whereby the Judicial Commission might be inspired to drop the complaint against Justice Prosser in order to avoid deciding the complaints against Judge Flanagan and the other state judges who have signed recall petitions against the Governor.\u00a0 If so, then they fail to appreciate how absurd it is to equate charges of physical assault (subject to the separate provisions of SCR 60.03) with the lawful exercise of a constitutional right.<\/p>\n

More likely, the drafters of the Complaint fully expect that the Judicial Commission will reject their complaint against Judge Flanagan while at the same time continuing the investigation of Justice Prosser.\u00a0 This eminently foreseeable result would serve their broader purpose of undermining the public\u2019s confidence in the Judicial Commission, by giving Judge Flanagan\u2019s critics an excuse to make unfounded claims of partisan bias.\u00a0 Other attacks on the integrity of the Judicial Commission by the group Media Trackers have proven groundless<\/a>, but that is unlikely to deter the steady drumbeat of criticism that various groups have directed at\u00a0the Judicial Commission.\u00a0 The goal of these critics is to influence public opinion through the vehicle of inflammatory allegations, and not to raise issues of legitimate concern relating to the administration of justice.<\/p>\n","protected":false},"excerpt":{"rendered":"

We live in interesting times.\u00a0 A segment of the general public is quick to forgive the killing of two young men in Slinger, Wisconsin and Sanford, Florida as the unavoidable consequence of the exercise of a constitutional right.\u00a0 Yet at the same time, state court judges\u00a0who have exercised their constitutional right of self-governance by signing 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