California, United States of America
The following excerpt is from People v. McGirt, E061614 (Cal. App. 2015):
A judge will not be deemed to have served as a lawyer in a proceeding if, when the judge was a lawyer, his or her interaction with the defendant was perfunctory. For example, a judge will not be deemed to have served as a lawyer in a proceeding where a prosecutor is serving as a judge pro tem, and in his or her role as a prosecutor had previously made an appearance when the defendant's sentence to state prison became effective following the appellate affirmance of defendant's sentence/conviction. Because the judge pro tem did not prosecute the prior case to conviction nor participate in the appeal, but "was simply in the courtroom to take care of the many matters calendared on that date" and knew nothing about the prior case, there was no basis for judicial disqualification. (People v. Bryan (1970) 3 Cal.App.3d 327, 342.)
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