What is the standard of review for a motion to disqualify from a hearing?

The standard of review on this issue is not entirely clear. Title 28 U.S.C. 2254(d) directs federal courts reviewing a state court decision to presume state court factual findings to be correct, if evidenced by a written "finding" or "opinion" or "other reliable and adequate written indicia." Here, the transcript of the hearing on the motion to disqualify is an adequate writing, Wainwright v. Witt, 469 U.S. 412, 430, 105 S.Ct. 844, 855, 83 L.Ed.2d 841 (1985), as would be the subsequent minute order. There are some exceptions to the presumption, none of which apply to the present case. However, the parties have not argued the applicability of 2254(d) so the record was not developed with that analysis in mind.