What happens when judges violate judicial canons?
Meet Judge Rangel. She’s an active Judge on an El Paso, Texas, District Court, but she’s considering her own Judge Judy style reality show as a retirement plan.
Unfortunately, during some of her hearings that were livestreamed on YouTube, she acted a little too much like a TV Judge.
We’re going to review a couple of these hearings, and I’ll explain what conduct you should expect from a Judge, as well as why Judge Rangel’s conduct led to her being publicly disciplined for misuse of public office.
The Zoom Hearings
Judge Rangel’s conduct, over the course of 4 hearings in particular, are what led to the complaints against her. These hearings occurred during the pandemic in 2020 and 2021, when all hearings were being conducted via Zoom and livestreamed on YouTube.
These hearings included 3 criminal cases and 1 civil case.
In each of these hearings, Judge Rangel lost her composure and used language that us mere mortals would have been held in contempt for. She disparaged the entire District Attorney’s Office, went on multiple lengthy diatribes, and even ridiculed a Defendant’s medical condition.
Because all of this was livestreamed on YouTube, the Court of Review watched these hearings for themselves. In their published opinion, the Court of Review said that words were not sufficient to capture the essence of Judge Rangel’s actions.
Here’s the wild thing about this case. The Court of Review entered an ORDER that all of these videos remain online until at least November 2024, and even hyperlinked each YouTube video within the opinion.
The Judicial Canons
Judges are required to follow a set of ethical principles and standards known as Judicial Canons.
Not canons, but canons. These canons are established to ensure the integrity, impartiality, and fairness of the judiciary system. They provide guidelines for judges to maintain public trust and confidence in the judicial system.
Violation #1 of Judicial Canon – Lack of Patience, Dignity, and Courtesy
To say that Judge Rangel demonstrated a lack of patience, dignity, and courtesy would be an understatement. There were a LOT of examples in the videos, but here’s an example:
https://www.youtube.com/live/_hvzgS9L2bc?si=UKYoRRftMQht6ypN&t=1176
Texas Judicial Canon 3B(4) says, “A judge shall be patient, dignified, and courteous to litigants, jurors, witnesses, lawyers, and others with whom the judge deals in an official capacity…”
The Court of Review said that Judges should “practice what they preach” when it comes to the language being used in the Courtroom.
Judge Rangel’s repeated use of the word “piss” and repeated yelling in loud angry tones at a captive audience who were not free to leave demonstrated her willful violation of this Judicial Canon.
But that isn’t the only Judicial Canon that Judge Rangel was found to have violated.
Violation #2 of Judicial Canon – Bias and Prejudice
If the Judge deciding a case holds a bias or prejudice against one of the parties, then how can that party ever hope to have a fair trial in that Court?
If a Judge realizes that they are biased or prejudiced, then they should recuse themselves so an impartial Judge can decide the case.
Unfortunately, Judge Rangel demonstrated, on video, her bias and prejudice against the entire El Paso County District Attorney’s office.
The Court of Review called Judge Rangel’s tone “elevated, sometimes shrill” and pointed out how she was “hopping in her seat” as she chastised the Assistant DA appearing in front of her. See for yourself:
https://www.youtube.com/live/I1Yc5otb-kU?si=vxLrb4l6xEq-2MrZ&t=5022
One of the fundamental bedrocks of Due Process requires an Impartial Decision-Maker. When a Judge remains on a case despite having bias or prejudice against a party, well that simply erodes the constitutional principles underlying our justice system.
Texas Judicial Canon 3B(5) says, “A judge shall perform judicial duties without bias or prejudice.”
It is pretty clear that Judge Rangel held bias and prejudice against the DA’s office, but that wasn’t the only party before her that she demonstrated bias and prejudice against.
Violation #3 of Judicial Canon – Breach of Public Confidence
A Defendant in a criminal case, who had not been convicted and retained the presumption of innocence, was suffering from some medical issue involving his groin. Whatever this issue was, it was apparently severe enough to cause both legs to be amputated.
During a preliminary hearing, Judge Rangel had this to say about the Defendant’s groin:
https://www.youtube.com/live/XFn0FpotMSI?si=C7gwdjHtQoezBhhi&t=2036
Texas Judicial Canon 2A says, “A judge should respect and comply with the law and should act at all times in a manner that promotes public confidence in the integrity and impartiality of the judiciary.”
Never mind the fear by the Defendant in that case of receiving a fair trial, but imagine the next Defendant on the docket. Do you think the next Defendant would have much faith in receiving a fair trial after hearing those statements? If our judiciary does not act with integrity and impartiality, then the public confidence in our Courts is eroded.
The Punishment
After 3 complaints were filed against Judge Rangel, the Texas State Commission on Judicial Conduct initiated an investigation. Judge Rangel appealed that Commission’s findings, which is what led us to the Court of Review’s ultimate opinion.
The Court of Review found that Judge Rangel violated at least 3 Judicial Canons. According to the Texas Constitution, Judges can only be punished for willful violations of the Judicial Canons.
Based on a thorough review of the videos, and the fact that the conduct persisted over several minutes rather than a split-second reaction, the Court of Review found that Judge Rangel intentionally misused her public office.
Judge Rangel was issued a Public Warning, was Ordered to complete 2 hours of additional education, and was Ordered to undergo 2 hours of mentoring with another Judge.
Read the punishment: https://www.scjc.texas.gov/media/47007/scr-22-0004-opinion-issued-11-03-23.pdf
Final Thoughts
Even though we’ve spent some time discussing some very public mistakes by a sitting Judge, this isn’t meant as any form of ridicule. I’m sure Judge Rangel regrets her conduct, and I’m sure that she used this as an opportunity to learn from her mistakes and become a better Judge.
Also, as a sitting Judge, she still deserves respect and I hope that anyone appearing in front of her affords her the respect that her position warrants. We’re all human, and we all make mistakes.
–Authored by Matthew L. Harris, Esq.,
Matthew Harris Law, PLLC – Civil Litigation Division
1101 Broadway, Lubbock, Texas, 79401-3303
Tel: (806) 702-4852 | Fax: (800) 985-9479