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· 9/3/2025

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.

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