21 Not wishing to stray too far into the merits, it seems to me that the likelihood of a reasonable apprehension of bias would increase in direct proportion as the involvement of the judge with a defendant church increased. On that point, I should record the existence of a strong line of American authorities, exemplified by Bryce v. Episcopal Church in the Diocese of Colorado, 289 F. 3d 648 (10th Cir. 2002), to the effect that “courts have consistently held that membership in a church does not create sufficient appearance of bias to require recusal” (at p. 660).
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