Caperton v. A.T. Massey Coal Co.

Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (2009), is a landmark decision of the United States Supreme Court.

After a jury verdict of $50 million against Massey Coal, the company’s chairman spent $3 million to support Brent Benjamin’s campaign for the West Virginia Supreme Court. Benjamin won the election and then cast the deciding vote to overturn the verdict. Caperton, the plaintiff, argued that Justice Benjamin’s participation violated due process.

Significance

Justice Kennedy’s 5-4 opinion held that the Due Process Clause requires judges to recuse themselves when a serious risk of bias exists based on the circumstances of the judge’s election campaign. The Court found that ’extreme facts’ — the extraordinary campaign contributions made by the party later appearing before the court — created a constitutionally unacceptable probability of actual bias. While the decision did not establish precise standards for judicial campaign finance, it recognized that due process imposes limits on judicial participation in cases involving major financial supporters.

Category

US Federal Case Law