Commonwealth v. Rangamar

CourtSupreme Court of The Commonwealth of The Northern Mariana Islands
DecidedMarch 16, 2026
Docket2024-SCC-0016-CRM
StatusPublished
AuthorCastro

This text of Commonwealth v. Rangamar (Commonwealth v. Rangamar) is published on Counsel Stack Legal Research, covering Supreme Court of The Commonwealth of The Northern Mariana Islands primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Rangamar, (N.M. 2026).

Opinion

E-FILED CNMI SUPREME COURT E-filed: Mar 16 2026 04:16PM Clerk Review: Mar 16 2026 04:16PM Filing ID: 78732085 Case No.: 2024-SCC-0016-CRM Judy Aldan

IN THE Supreme Court OF THE

Commonwealth of the Northern Mariana Islands COMMONWEALTH OF THE NORTHERN MARIANA ISLANDS, Plaintiff-Appellee, v. SERGIO M. RANGAMAR, Defendant-Appellant. Supreme Court No. 2024-SCC-0016-CRM

SLIP OPINION Cite as: 2026 MP 3 Decided March 16, 2026

CHIEF JUSTICE ALEXANDRO C. CASTRO ASSOCIATE JUSTICE JOHN A. MANGLOÑA JUSTICE PRO TEMPORE PERRY B. INOS

Superior Court Criminal Case No. 23-0089-CR Associate Judge Teresa K. Kim-Tenorio, Presiding Commonwealth v. Rangamar, 2026 MP 3

CASTRO, C.J.: ¶1 Sergio M. Rangamar was convicted of multiple offenses stemming from an alleged assault. He argues that the trial judge should have been disqualified under 1 CMC § 3308(a) because the judge presided over the Drug Court Program in which the key witness participated. He also contends the court violated his due process rights by denying his motion to compel disclosure of the key witness’s Drug Court records without conducting an in camera review. We hold that the judge should have recused herself under Section 3308(a). We therefore vacate the judgment and remand the case for further proceedings before a different judge. I. FACTS AND PROCEDURAL HISTORY ¶2 Amanda Desebel (“Desebel”) alleged that Sergio M. Rangamar (“Rangamar”) fired a pellet gun in her direction while she was walking near his residence, striking her once in the ankle. Desebel testified she identified Rangamar based on prior familiarity with him. Another individual walking with her, Roderick Blanco, did not independently name the shooter at the scene but later identified Rangamar through a police identification procedure. ¶3 The Commonwealth charged Rangamar shortly after the incident. In an unrelated matter, Desebel was accepted into the Commonwealth’s Drug Court Program (“Drug Court”) on September 21, 2023. The judge assigned to Rangamar’s case also presided over Drug Court and conducted regular review hearings at which Desebel appeared. ¶4 Rangamar moved to disqualify the trial judge, asserting that the ongoing Drug Court oversight of Desebel created an appearance of partiality because Desebel was a key witness. The trial court denied the motion. ¶5 Rangamar also sought records connected to Desebel’s Drug Court participation and filed a motion to compel. The Commonwealth opposed the motion, arguing that the materials sought were not within the prosecution’s possession and, to the extent they existed, were maintained by the Judiciary or third-party treatment providers. The trial court denied the motion without conducting an in camera review. ¶6 After the Commonwealth filed a second amended information, the case proceeded as a bench trial. Before trial, Rangamar moved for reconsideration of the denial of disqualification, citing the change in posture and intervening authority; the trial court denied reconsideration. ¶7 On February 2, 2024, Rangamar was found guilty of one count of assault and battery, one count of assault, and two counts of disturbing the peace. Rangamar timely appealed, challenging the denial of his motions for judicial disqualification under 1 CMC § 3308(a) and in camera review of Desebel’s Drug Court records. Commonwealth v. Rangamar, 2026 MP 3

II. JURISDICTION ¶8 We have appellate jurisdiction over final judgments and orders of the Superior Court pursuant to Article IV, Section 3 of the Constitution of the Northern Mariana Islands and 1 CMC § 3102(a). III. STANDARD OF REVIEW ¶9 We review the denial of a motion for judicial disqualification for abuse of discretion. Commonwealth v. Caja, 2001 MP 6 ¶ 2. Rulings on motions to compel discovery are reviewed de novo to the extent they turn on the scope of constitutional due process protections. Commonwealth v. Campbell, 4 NMI 11, 15 (1993). If the rulings comply with constitutional mandates, they are reviewed for abuse of discretion. Commonwealth v. Hossain, 2010 MP 21 ¶ 9. IV. DISCUSSION A. Disqualification Under 1 CMC § 3308(a) ¶ 10 Judicial disqualification under 1 CMC § 3308(a) turns on a single, objective inquiry—whether a reasonable person, fully informed of the relevant facts, would question impartiality. Bank of Saipan v. Superior Court, 2002 MP 16 ¶ 29; Saipan Lau Lau Dev., Inc. v. Superior Court, 2000 MP 12 ¶ 5. This objective test is often described as the reasonable person standard. 1. The Reasonable Person Standard and the Limits of Liteky ¶ 11 In applying the reasonable person standard, courts have long recognized that prior judicial exposure to a party or witness does not ordinarily require disqualification. Judges inevitably encounter the same individuals and factual contexts through the ordinary performance of their duties. Courts have a duty to hear and decide matters assigned to them. See United States v. Holland, 519 F.3d 909, 912 (9th Cir. 2008) (noting that the duty to sit derives from the judicial power and obligates judges to hear assigned cases absent a valid ground for recusal); United States v. Snyder, 235 F.3d 42, 45 (1st Cir. 2000) (explaining that a judge has as strong a duty to sit when there is no legitimate reason to recuse as he does to recuse when the law and facts require it). Recusal rules are therefore applied with restraint. ¶ 12 In Liteky v. United States, the Supreme Court articulated this practical limit, holding that opinions formed in the course of judicial proceedings “almost never” warrant recusal absent deep-seated favoritism or antagonism that would make fair judgment impossible. 510 U.S. 540, 555 (1994). If ordinary judicial exposure were sufficient to mandate recusal, routine adjudication would become untenable. See In re Estate of Malite, 2011 MP 4 ¶¶ 57–58 (citing Liteky for the conclusion that opinions formed from court proceedings are ordinarily immune unless they result in “pervasive bias”). ¶ 13 Liteky’s rule, however, is confined to opinions formed during adjudication—rulings, courtroom statements, and impressions derived from evidence and argument presented in prior proceedings. Id. at 555. It does not insulate exposure to information acquired outside the evidentiary presentation of the case being tried. When a judge acquires knowledge in a setting where the Commonwealth v. Rangamar, 2026 MP 3

information was not subjected to adversarial testing, the concern is no longer whether the judge harbors deep-seated favoritism or antagonism. The inquiry instead becomes objective: whether that exposure creates a risk of partiality sufficient to undermine public confidence in the neutrality of the proceeding. ¶ 14 Rippo v. Baker confirms that recusal doctrine turns on objective risk rather than proof of actual prejudice. 580 U.S. 285 (2017). There, the Nevada Supreme Court rejected a bias claim because the defendant had not shown that the trial judge was “actually biased.” Id. at 286. The Supreme Court of the United States vacated, explaining that this was the wrong inquiry. Due process may require recusal even without proof of subjective animus. The proper question is whether, considering all the circumstances, “the probability of actual bias on the part of the judge or decisionmaker is too high to be constitutionally tolerable.” Id. (quoting Withrow v. Larkin, 421 U.S. 35, 47 (1975)). ¶ 15 Commonwealth v. Kaipat, 1996 MP 20, illustrates this distinction in a bench trial context. There, the presiding judge had previously overseen the jury trial of the defendant’s brother. Id. ¶¶ 4–6.

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Commonwealth v. Rangamar, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-rangamar-nmariana-2026.