Snyder Vs. Dist. Ct. (Snyder), 83651

Petitioner Raymond Max Snyder filed an emergency, pro se original petition for a writ of mandamus or prohibition to challenge a district court order denying his motion to disqualify Senior Judge Robert Estes from presiding over divorce and post‑decree enforcement proceedings.
Snyder alleged the judge was prejudiced and thus lacked jurisdiction, citing: reduction of an order to judgment despite a pending appeal, allowance of allegedly "forged" orders by opposing counsel, and continued involvement despite Snyder’s complaints to the Commission on Judicial Discipline.
Snyder submitted a flash drive (Exhibit 9) purportedly containing audio/video of a hearing; the Supreme Court struck the exhibit as improperly submitted under NRAP rules and declined to review it.
The Supreme Court considered the petition and supporting documents and emphasized that writ relief is extraordinary and discretionary, and the petitioner bears the burden to show relief is warranted.
The Court concluded Snyder did not demonstrate disqualification was warranted under Nevada law and precedent, denied the petition, and ordered the clerk to return the improperly filed exhibit.

Issue	Snyder's Argument	Respondent's Argument	Held
Whether extraordinary writ relief is warranted to disqualify the judge	Judge Estes was biased and lacked jurisdiction because of alleged prejudicial acts	Snyder failed to meet the heavy burden for discretionary writ relief; no demonstrated legal basis for disqualification	Denied — writ relief not warranted
Whether the judge’s trial rulings and conduct during proceedings establish disqualifying bias	Rulings and actions show prejudice and justify disqualification	Rulings during official proceedings do not establish legally cognizable bias	Denied — rulings/actions in proceedings insufficient for disqualification
Whether filing complaints with the judicial discipline commission requires recusal	Prior complaints show judge’s bias and mandate recusal	A party’s complaint to disciplinary authorities does not automatically disqualify a judge	Denied — complaints alone do not mandate disqualification
Whether improperly submitted exhibits (flash drive) could be considered	Exhibit contains proof of bias and should be reviewed	Exhibit was improperly submitted under NRAP and must be stricken	Court struck exhibit and declined to review it

Pan v. Eighth Judicial Dist. Court, 120 Nev. 222, 88 P.3d 840 (2004) (writ relief is discretionary and the petitioner bears the burden to show relief is warranted)
Smith v. Eighth Judicial Dist. Court, 107 Nev. 674, 818 P.2d 849 (1991) (writ relief is extraordinary and within the court’s sole discretion)
Rivero v. Rivero, 125 Nev. 410, 216 P.3d 213 (2009) (a judge is presumed unbiased; disqualification standards explained)
In re Petition to Recall Dunleavy, 104 Nev. 784, 769 P.2d 1271 (1988) (disqualifying bias generally must come from an extrajudicial source)
In re Disqualification of Kilpatrick, 546 N.E.2d 929 (Ohio 1989) (filing a complaint with disciplinary authorities does not automatically disqualify a judge)