Ogden v. Ogden

OPINION

BRYNER, Justice.

I,. INTRODUCTION

Douglas Ogden appeals the custody and property division provisions of a divorce decision and challenges the trial court's refusal to disqualify the child eustody investigator for apparent gender bias because her yellow-page listing advertised her as an attorney who was a "voice for women and children." Although we find that the yellow-page listing gives rise to a reasonable appearance of bias that warranted disqualification, we conclude that failure to disqualify the custody investigator amounted to harmless error. But we further conclude that…