Key legal question
Whether the cantonal judges were biased because Dr. Bruno Gutzwiller was both a Landeskirchenrat president and a cantonal judge.
Extracted holding
No appearance of bias arose from the dual role alone; no special circumstances showed influence on the panel.
Extracted reasoning
The mere fact that a member of a lower authority also serves as a judge in a higher court does not by itself disqualify the other judges. The appellant did not show participation or influence in the impugned judgment.