Caperton v. A. T. Massey Coal Co., Inc.

Background

A group of business owners (Caperton) won a $50 million jury verdict against a coal company (Massey). Massey’s chairman, Don Blankenship, spent about $3 million supporting a judicial candidate, Brent Benjamin, in a state supreme court election that occurred while Caperton’s appeal was pending. Benjamin denied three recusal motions and then participated in decisions that reversed the $50 million verdict.

Reasoning

The central question was whether the Constitution’s promise of fair process requires a judge to step aside when a person with a direct stake in the case used large, campaign-linked spending to help elect the judge. The Court applied an objective test — not requiring proof of actual bias — asking whether the contributions were significant and disproportionate compared with total campaign spending, whether they affected the election outcome, and whether timing made it foreseeable the donor’s case would reach that judge. On these facts the Court found a serious, constitutionally intolerable risk of bias and held recusal was required.

Real world impact

The ruling means that in rare, extreme situations where a litigant or its principal has an outsized role in electing a judge while a related case is pending, that judge must be disqualified. Most recusal disputes will continue to be handled by state codes of conduct; the constitutional rule will be confined to exceptional cases and does not decide the merits of the original $50 million judgment.

Dissents or concurrances

Several Justices dissented and warned the new constitutional rule is vague, may invite many recusal challenges, and could unsettle judicial elections and doctrine; they emphasized deference to state codes and concern about open-ended standards.