Miller v. Carroll


Appeal No. 2017AP2132 (WI Ct. App., 2019)


Custody ordered reversed where the trial judge accepted a Facebook “friend” request from the mother after the trial, but before issuing a written decision. While not establishing a bright line, the appellate court held that Judge Bitney’s actions “created a great risk of actual bias, resulting in the appearance of partiality.”

[ Full Opinion ]