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Wolfkill Feed & Fertilizer Corp. v. Martin
Citation: 14 P.3d 877Docket: 18937-6-III
Court: Court of Appeals of Washington; December 26, 2000; Washington; State Appellate Court
Wolfkill Feed and Fertilizer Corporation sued James and Wendy Martin and CTM, Inc. for $9,000 due to breach of contract. After mandatory arbitration ruled in favor of Wolfkill, the Adams County Superior Court awarded Wolfkill $15,355.61 upon de novo review. Martin appealed, claiming the trial judge erred by not recusing himself or sealing Wolfkill’s trial brief, which allegedly violated MAR 7.2(b)(1) by referring to the arbitration result. The court noted that under MAR 7.2(b), no reference to arbitration should occur during the trial. Despite Wolfkill's brief mentioning the arbitration and the amount in dispute, the judge stated he would disregard any inappropriate content and did not believe recusal was necessary since he was unaware of the arbitration award specifics. The court affirmed its decision, concluding that the judge did not abuse his discretion in denying Martin’s requests. The trial court ruled in favor of Wolfkill, and Martin appealed, arguing that the judge should have recused himself after reading Wolfkill's trial brief, which mentioned the arbitration outcome. Martin claimed that recusal was necessary to prevent bias influenced by the arbitration award and to uphold fairness for litigants. The court maintained that recusal is at the judge's discretion and can only be overturned if there's a clear abuse of that discretion. The court found no such abuse, noting that while Wolfkill's brief referenced its status as the winning party, it did not disclose the specifics of the arbitrator's award, thus only partially violating MAR 7.2(b). The rules allow the trial judge to know the arbitration's general result without detailing the award amount. The court affirmed its intent to review the case impartially, ensuring that any reference to arbitration would not affect its decision-making. Martin's allegations of bias were deemed speculative, lacking evidence to suggest that the court did not base its decision solely on admissible evidence. The court confirmed the absence of grounds for recusal or sanctions, ultimately affirming the trial court's ruling.