In re Nadeau, 178 A.3d 495

Judge Robert M.A. Nadeau (York County Probate Court) presided over a guardianship matter in which he had appointed Kerri Gottwald guardian of Devora Gavel’s minor child.
Gavel posted negative comments about Judge Nadeau on social media; a person using Judge Nadeau’s wife’s name responded. Judge Nadeau knew of the postings.
Gottwald sought child support from Gavel; Judge Nadeau’s May 2016 scheduling order noted his potential disqualification if a hearing were required.
On July 5, 2016, at a child support hearing, Gavel moved to recuse; Judge Nadeau said he had credibility concerns and that he would have to recuse if an evidentiary hearing were required, but he nonetheless negotiated and entered the child support order after the parties agreed to figures.
Gavel complained to the Committee on Judicial Responsibility and Disability alleging intentional refusal to recuse; the Committee reported the matter to the Maine Supreme Judicial Court.
The Court found Judge Nadeau violated Rule 2.11(A) (requirement to disqualify for personal bias) and imposed a public reprimand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Judge Nadeau was required to recuse under Rule 2.11(A) for personal bias	Gavel: social media attacks (and a household response) created personal bias; judge acknowledged bias and should have recused	Nadeau: matter was largely a ministerial/settlement process; he acted as a settlement judge and parties effectively agreed to avoid an evidentiary hearing	Court: Required recusal. Judge acknowledged bias from extra‑judicial social media exchange; Rule 2.11(A)(1) mandates disqualification for personal bias and parties cannot waive it
Whether participation in settlement/negotiation cured recusal concerns	Gavel/Committee: active judicial involvement in negotiating terms despite bias does not cure the disqualification	Nadeau: characterized role as settlement judge and argued no evidentiary hearing occurred requiring credibility determinations	Court: Participation did not cure the obligation to recuse once personal bias existed; judge’s involvement was substantial and therefore contrary to the Rule
Whether conduct warranted discipline and nature of sanction	Committee: discipline necessary to deter and preserve public confidence	Nadeau: mitigation — no longer a judge; previously disciplined; ongoing suspension from practice of law	Court: Discipline warranted but tempered by fact he no longer holds judicial office and is suspended from law practice; imposed public reprimand

In re Nadeau, 168 A.3d 746 (Me. 2017) (framework for sanctions in prior judicial discipline proceedings)
State v. Murphy, 10 A.3d 697 (Me. 2010) (courts should avoid recusal when parties attempt to manufacture it; but unfounded claims differ from valid bias concerns)
Dalton v. Dalton, 99 A.3d 723 (Me. 2014) (knowledge gained in prior proceedings generally is not sufficient ground for recusal)
In re J.R. Jr., 69 A.3d 406 (Me. 2013) (similar statement that prior judicial knowledge ordinarily does not require recusal)