- “A reasonable person aware of the facts could not reasonably entertain a doubt…that Judge (Samuel) McAdam would be biased in this matter.” – Judge John Hinely
A Yolo County Superior Court judge has rejected claims of judicial bias raised by county prosecutors who sought to disqualify Judge Samuel McAdam from presiding over the second trial of Carlos Dominguez, with an outside judge concluding the prosecution failed to establish that McAdam could not be impartial.
In an order filed Monday, Sutter County Superior Court Judge John Hinely denied the prosecution’s challenge after reviewing the written record, concluding that the legal standard for disqualification was not met.
“A reasonable person aware of the facts could not reasonably entertain a doubt [or think] that Judge (Samuel) McAdam would be biased in this matter,” Hinely wrote. “Accordingly, the people’s challenge … is denied.”
The ruling clears the way for McAdam to continue overseeing the case as it moves toward a second trial following a mistrial last year.
Dominguez, a former UC Davis student, is accused of stabbing three people in Davis during the spring of 2023. Prosecutors allege that Dominguez fatally stabbed David Breaux in Central Park on April 27, 2023, killed Karim Najm the following day in Sycamore Park, and critically injured Kimberlee Guillory on May 1, 2023. Guillory survived the attack.
Dominguez admitted to the stabbings but pleaded not guilty by reason of insanity, arguing that untreated schizophrenia placed him in a state of active psychosis at the time of the attacks.
His first trial ended in July 2025 after jurors acquitted him of first-degree murder but deadlocked on the remaining counts, including second-degree murder and attempted murder. The mistrial resulted in the case being scheduled for retrial, which Judge McAdam was assigned to preside over.
Prosecutors formally sought Judge McAdam’s disqualification in December, filing a written verified statement objecting to his continuing to hear the case under California Code of Civil Procedure section 170.1.
In the motion, Chief Deputy District Attorney Melinda Aiello alleged that the cumulative impact of McAdam’s rulings and courtroom conduct demonstrated bias against the prosecution.
“The People have given every benefit of doubt,” Aiello wrote. “However now, the cumulative effect of Judge McAdam’s conduct has demonstrated a clear and unmistakable bias.”
Aiello argued that the prosecution’s concerns were not limited to a single ruling or incident but reflected a broader pattern that, in the People’s view, compromised their ability to receive a fair trial.
“For the reasons so stated, the People respectfully request that Judge McAdam be disqualified from this case and that the case be reassigned to an impartial judge,” she wrote.
Under California law, once a judge is challenged under section 170.1, the judge may file a verified answer contesting the allegations, after which the matter is reviewed by a different judge assigned by the Judicial Council. That review was conducted by Judge Hinely of Sutter County.
In his verified answer opposing disqualification, Judge McAdam disputed the prosecution’s claims and denied that his actions reflected bias or prejudice. Addressing the allegation that he had “engaged in conduct a reasonable person would perceive as an appearance of bias,” McAdam rejected the characterization.
“I have made lawful court decisions and have exercised reasonable control of the proceedings,” McAdam wrote. “The parties have received fair hearings.”
McAdam emphasized that his role as a trial judge required making discretionary rulings, including evidentiary and procedural decisions, and that disagreement with those rulings did not equate to bias. He also addressed the posture of the case moving forward, noting that the mistrial necessitated a fresh approach to the proceedings.
“I have an open mind as to all matters in this case, especially because this matter is to be set for retrial,” McAdam wrote. “I ask the reviewing court to find that the People have not met its burden and that I am not disqualified from this case.”
In his ruling, Judge Hinely carefully reviewed the prosecution’s claims, the judge’s response, and the legal standards governing judicial disqualification. Hinely repeatedly emphasized that adverse rulings, even when numerous, do not establish bias unless they demonstrate objective prejudice or a reasonable appearance that the judge cannot be fair.
Hinely noted that the prosecution failed to identify legal authority establishing that Judge McAdam’s rulings constituted error warranting disqualification, writing that “the People provided no legal authority that Judge McAdam’s ruling constituted legal error and sought no appellate review.”
The absence of appellate challenge to the contested rulings weighed against the prosecution’s claim that those rulings reflected bias rather than discretionary judicial decision-making.
“The evidence presented by the People does not establish objective bias or prejudice against them,” Hinely wrote.
Instead, Hinely concluded that the record demonstrated “the People’s disagreement with Judge McAdam’s interpretation of, and application of, law to the facts of the underlying case.”
Throughout the 15-page order, Hinely addressed multiple categories of alleged bias raised by the prosecution, including evidentiary rulings, control of courtroom proceedings, comments made during trial management conferences, and decisions regarding continuances and the scope of expert testimony.
In each instance, Hinely found that the prosecution had failed to meet the heavy burden required for disqualification under California law.
Under the governing standard, a judge must be disqualified if “a reasonable person aware of the facts might reasonably entertain a doubt that the judge would be able to be impartial.”
Hinely concluded that this standard was not satisfied, writing that mere disagreement with judicial decisions does not establish an appearance of bias.
The order stated that disqualification requires more than conclusions or assertions, and that “mere statements or conclusions that the judge is biased do not meet this burden.”
Hinely ultimately ordered that the prosecution’s challenge to Judge McAdam “is DENIED,” allowing McAdam to remain assigned to the case.
The ruling comes as Dominguez prepares to return to court Thursday for a hearing at which a date for the second trial is expected to be set. Because Dominguez entered a plea of not guilty by reason of insanity, the retrial is expected to again involve complex questions regarding mental illness, competency, and criminal responsibility.
The Dominguez case has drawn intense public attention in Davis and beyond, given the random nature of the attacks and the impact on the community. Breaux, a well-known local fixture often referred to as the “compassion guy,” was widely recognized for his presence in Central Park. Najm was a UC Davis student whose death sparked renewed concerns about campus safety. Guillory, who was living in a tent at the time of the attack, survived after sustaining severe injuries.
Prosecutors have argued that Dominguez carefully planned the attacks, while the defense has maintained that he was experiencing florid psychosis and lacked the capacity to form criminal intent. Those issues will again be central in the retrial.
Judge McAdam’s continued assignment means that the same judge who presided over the first trial will oversee pretrial motions and evidentiary rulings in the second. The prosecution’s unsuccessful disqualification effort ensures that those proceedings will move forward without a change in judicial assignment.
The ruling also underscores the high bar required to remove a judge over allegations of bias in California courts, particularly where the claimed bias is rooted in trial management and legal rulings rather than extrajudicial conduct.
With the disqualification issue resolved, the Dominguez case now returns squarely to the trial calendar, setting the stage for a second jury to weigh the facts surrounding one of the most closely watched criminal cases in Yolo County history.
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