A judge is not allowed to consider evidence that was not presented at the hearing, but he is allowed to do his own research on the law and to cite any cases he finds.
I wonder if, during his perusal of the internet that he happened to find this Obama birth certificate?
Given the proclivity for fake stuff to show up on the internet nowadays, I wouldn't want the judge to base his decision on a fraudulent document. One would think they would needfully rely on some sort of process of certification or something? Wouldn't you? :)