Any right to confrontation and cross-examination implicated by the due process clause is relaxed at a suppression hearing. Ultimately, due process is flexible and calls for such procedural protections as the particular situation demands. In this case, the arresting officer’s death rendered him unavailable to testify at the suppression hearing. However, testimony by a second officer established that the recording from the dashboard camera on the arresting officer’s squad car accurately and continuously documented the portions of the stop observed by the second officer and the audio portion of that same recording captured a statement made by the arresting officer to the defendant. The circuit court’s reliance on that hearsay statement did not offend the reduced standard for due process of law required at a suppression hearing. State v. Zamzow, 2017 WI 29, 374 Wis. 2d 220, 892 N.W.2d 637, 14-2603. Denying a defendant the opportunity to present the defendant’s case-in-chief in a termination of parental rights proceeding is a structural error, the consequence of which is an automatic new trial. State v. C.L.K., 2019 WI 14, 385 Wis. 2d 418, 922 N.W.2d 807, 17-1413. The test for whether this state can, consistent with due process, exercise its police power to regulate an out-of-state entity is whether the out-of-state entity has incidents and requires activities within the state intimately related to local welfare. Payday Loan Resolution, LLC v. DFI, 2019 WI App 28, 388 Wis. 2d 117, 931 N.W.2d 279, 18-0821. Constitutional due process protections are unavailable to probationary employees. A probationary employee has no more than a unilateral expectation of completing the employee’s probation and being hired as a permanent employee. That expectation is insufficient for procedural due process protections to attach. An employee must instead have a legitimate claim of entitlement to the position to give rise to a property interest warranting protection. State ex rel. Massman v. City of Prescott, 2020 WI App 3, 390 Wis. 2d 378, 938 N.W.2d 602, 18-1621. The right to an impartial judge is fundamental to our notion of due process. A reviewing court presumes that a judge has acted fairly, impartially, and without bias. To overcome that presumption, the burden is on the party asserting judicial bias to show bias by a preponderance of the evidence. In evaluating whether a party has rebutted the presumption, courts have taken both a subjective and objective approach. A judge must disqualify himself or herself from a case if the judge subjectively determines that the judge is unable to remain impartial. To assess whether the probability of actual bias rises to the level of a due process violation, courts ask whether there is a serious risk of actual bias based on objective and reasonable perceptions. It is the exceptional case with extreme facts that rises to the level of a serious risk of actual bias. Miller v. Carroll, 2020 WI 56, 392 Wis. 2d 49, 944 N.W.2d 542, 17-2132. The extreme facts of this case, in which a circuit court judge had an undisclosed social media connection with a litigant, rebutted the presumption of judicial impartiality and established a due process violation. Miller v. Carroll, 2020 WI 56, 392 Wis. 2d 49, 944 N.W.2d 542, 17-2132. To establish specific personal jurisdiction, there must be some act by which the defendant purposefully availed itself of the privilege of conducting activities within the forum state, thus invoking the benefits and protections of its laws. The unilateral activity of those who claim some relationship with a nonresident defendant cannot satisfy the requirement of contact with the forum state. This purposeful availment requirement ensures that a defendant will not be haled into a jurisdiction solely as a result of random, fortuitous, or attenuated contacts, or of the unilateral activity of another party or a third person. In this case, the defendant’s sole contact with Wisconsin was its contract with a Wisconsin business. A corporation’s contract with an out-of-state party alone is not enough to automatically establish the requisite minimum contacts needed to satisfy the 14th amendment’s due process clause. CITGO Petroleum Corp. v. MTI Connect, LLC, 2020 WI App 57, 394 Wis. 2d 126, 949 N.W.2d 577, 18-1555. The due process requirement of Loudermill, 470 U.S. 532 (1985), does not require any formal written notice listing all policy violations at issue in a municipality’s discipline action against an employee, or that an employee’s right to respond to those violations be available during a formal contested hearing before a neutral adjudicator prior to the discipline. In fact, Loudermill holds to the contrary. Namely, when sufficient post-disciplinary procedures are available, due process is satisfied as long as an employee is provided notice and given some opportunity to respond to the alleged charges against the employee before discipline is imposed. Green Bay Professional Police Ass’n v. City of Green Bay, 2021 WI App 73, 399 Wis. 2d 504, 966 N.W.2d 107, 21-0102. There is no due process right to impartial decision-makers when a legislative body like a village board enacts, repeals, or amends a generally applicable law like a zoning ordinance. When adjudicative acts are involved, procedural due process requires impartial decision-makers. When legislative actions are at issue, however, those affected by legislation are not entitled to any process beyond that provided by the legislative process. Miller v. Zoning Board of Appeals, 2023 WI 46, 407 Wis. 2d 678, 991 N.W.2d 380, 21-1764. A public employee terminable only for cause has a property interest in continued employment. Loudermill, 470 U.S. 532 (1985), generally entitles such an employee to notice of the charges, an explanation of the evidence supporting them, and some pre-termination opportunity to respond. The scope and the nature of the pre-termination procedures can vary depending on the nature of the post-termination proceedings and the interests that are implicated. Loudermill does not require an explanation of the reasons discharge is a chosen punishment as opposed to suspension or something lesser. Rather, Loudermill just requires an explanation of the basic reasons the employee is being disciplined. Andrade v. City of Milwaukee Board of Fire & Police Commissioners, 2024 WI 17, 411 Wis. 2d 340, 5 N.W.3d 261, 20-0333. The Wisconsin Medical Examining Board does not deny due process by both investigating and adjudicating a charge of professional misconduct. Withrow v. Larkin, 421 U.S. 35, 95 S. Ct. 1456, 43 L. Ed. 2d 712 (1975). Due process does not disqualify an agency as a decision maker merely because of familiarity with the facts of a case. Hortonville Joint School District No. 1 v. Hortonville Education Ass’n, 426 U.S. 482, 96 S. Ct. 2308, 49 L. Ed. 2d 1 (1976). Utility customers’ due process rights were violated when the utility shut off service for nonpayment without advising the customers of available administrative procedures. Memphis Light, Gas & Water Division v. Craft, 436 U.S. 1, 98 S. Ct. 1554, 56 L. Ed. 2d 30 (1978). A father’s acquiescence in his daughter’s desire to live with her mother in California did not confer jurisdiction over the father in California courts. Kulko v. Superior Court, 436 U.S. 84, 98 S. Ct. 1690, 56 L. Ed. 2d 132 (1978). The due process clause was not violated when the Internal Revenue Service (IRS) monitored a conversation with the defendant in violation of IRS rules. United States v. Caceres, 440 U.S. 741, 99 S. Ct. 1465, 59 L. Ed. 2d 733 (1979). A state may not exercise quasi in rem jurisdiction over a defendant having no forum contacts by attacking the contractual obligation of the defendant’s insurer licensed in the state. Rush v. Savchuk, 444 U.S. 320, 100 S. Ct. 571, 62 L. Ed. 2d 516 (1980). The termination of appointed assistant public defenders, who were neither policymakers nor confidential employees, solely on grounds of political affiliation was a denial of 1st and 14th amendment rights. Branti v. Finkel, 445 U.S. 507, 100 S. Ct. 1287, 63 L. Ed. 2d 574 (1980). Segregation confinement of a prisoner without prior hearing may violate due process if postponement of procedural protections is not justified by apprehended emergency conditions. Hughes v. Rowe, 449 U.S. 5, 101 S. Ct. 173, 66 L. Ed. 2d 163 (1980). When an accident involving only Wisconsin residents occurred in Wisconsin, the fact that the decedent had been employed in Minnesota conferred jurisdiction on Minnesota courts, and Minnesota insurance law was applicable. Allstate Insurance Co. v. Hague, 449 U.S. 302, 101 S. Ct. 633, 66 L. Ed. 2d 521 (1981).