ROBB, C.J.
Finally, Cristiani argues the trial court abused its discretion because “[l]eading up to and through the trial, a pattern developed in the [trial] [c]ourt’s rulings, in which Money prevailed on virtually every substantive evidentiary objection.” Appellant’s Corrected Br. at 27. Cristiani describes several instances, noting that “[t]aken alone, none of these issues would merit reference . . . . But they – together with the [other issues on appeal] – demonstrate an uneven playing field in the proceedings . . . .” Id. at 28. This amounts to an allegation of judicial bias of the trial judge.
The law presumes a judge is unbiased. In re Edwards, 694 N.E.2d 701, 711 (Ind. 1998). To overcome this presumption, a party must establish “actual personal bias.” Moore v. Liggins, 685 N.E.2d 57, 63 (Ind. Ct. App. 1997). Further, a party alleging judicial bias must demonstrate that “the trial judge’s action and demeanor crossed the barrier of impartiality and prejudiced the party’s case.” J.M. v. M.A., 928 N.E.2d 230, 237 (Ind. Ct. App. 2010) (alteration and citation omitted). Adverse rulings alone are insufficient to show bias or prejudice. Id.; Moore, 685 N.E.2d at 63 (“Adverse rulings are insufficient to show bias per se.”).
By conceding their relative unimportance standing alone, Cristiani concedes the trial court did not abuse its discretion in any of these singular evidentiary decisions, but argues that cumulatively, each is an example of the trial judge’s bias and exercise of discretion in a manner that prejudiced Cristiani.
However, Cristiani does not demonstrate an actual personal bias of the trial judge. Cristiani describes adverse rulings, but no more. There is no indication in the record and Cristiani does not present facts or specific arguments that the trial judge was motivated by any concerns other than the prevailing law in making her discretionary rulings. Accordingly, Cristiani has failed to overcome our presumption the trial judge is unbiased.
Further, Cristiani highlights less than ten incidents, which, Cristiani argues, is tantamount to a pattern. We disagree, viewing these highlighted incidents in the context of a lengthy pretrial period and jury trial, in which a trial court may have made scores of evidentiary rulings.
RILEY, J., and BROWN, J., concur.