Question juridique clé
Whether the prosecutor had to be recused for apparent bias under constitutional and procedural impartiality rules
Solution extraite
No concrete objective circumstances showed an appearance of bias; prior adverse rulings in a similar matter did not require recusal.
Motifs extraits
A prosecutor may handle a second complaint involving the same parties and similar offenses; prior participation is not enough absent objective signs of prejudgment. The new complaint concerned a different writing, and any replacement prosecutor would also see the prior non-prosecution decision in the file.