Case Brief: Caperton v. Massey
Case Brief
1. CASE: Caperton v. A. T. Massey Coal Co. Inc. 556 U.S. 868 (2009)
2. FACTS:
A West Virginia jury issued a verdict against respondents (“Massey”) in the amount of $50 million.
After the verdict, knowing that the West Virginia’s Supreme Court of Appeals would consider the appeal, Blankenship, the chairman, CEO and president of Massey contributed $3 million to help
Benjamin run for office in that court in West Virginia’s 2004 judicial election. Benjamin won the election in a close race.
3. PROCEDURAL HISTORY:
After Benjamin took office, the West Virginia Supreme Court heard Massey’s appeal. Petitioners
(“Caperton”) requested that Benjamin recuse himself but he refused to withdraw. The court reversed the $50 million verdict against Massey. Caperton sought rehearing, and again sought
Benjamin’s recusal. Benjamin again denied the second recusal motion. The court granted rehearing and the divided court again reversed the jury verdict in a 3-2 decision, prior to which the recusal motion was sought by Caperton and denied by Benjamin for a third time.
4. ISSUE(S):
Whether the Due Process Clause of the14th Amendment was violated when one of the justices in the majority denied a recusal motion, the basis for which was that he had received significant campaign contributions from, and through the efforts of, the corporation's principal officer.
5. HOLDING(S):
There is a serious and objective risk of actual bias when a person with a personal stake in a particular case has a significant and disproportionate influence in placing the judge on the case by raising funds or directing the judge’s election campaign when the case was pending or imminent, which risk creates a probability of bias that threatened due process.
6. RATIONALE:
The Court identified additional instances, which require recusal where the “probability of actual bias” on the part of the judge is too high to be constitutionally tolerable. In this case, (1) Though not a bribe or
1. CASE: Caperton v. A. T. Massey Coal Co. Inc. 556 U.S. 868 (2009)
2. FACTS:
A West Virginia jury issued a verdict against respondents (“Massey”) in the amount of $50 million.
After the verdict, knowing that the West Virginia’s Supreme Court of Appeals would consider the appeal, Blankenship, the chairman, CEO and president of Massey contributed $3 million to help
Benjamin run for office in that court in West Virginia’s 2004 judicial election. Benjamin won the election in a close race.
3. PROCEDURAL HISTORY:
After Benjamin took office, the West Virginia Supreme Court heard Massey’s appeal. Petitioners
(“Caperton”) requested that Benjamin recuse himself but he refused to withdraw. The court reversed the $50 million verdict against Massey. Caperton sought rehearing, and again sought
Benjamin’s recusal. Benjamin again denied the second recusal motion. The court granted rehearing and the divided court again reversed the jury verdict in a 3-2 decision, prior to which the recusal motion was sought by Caperton and denied by Benjamin for a third time.
4. ISSUE(S):
Whether the Due Process Clause of the14th Amendment was violated when one of the justices in the majority denied a recusal motion, the basis for which was that he had received significant campaign contributions from, and through the efforts of, the corporation's principal officer.
5. HOLDING(S):
There is a serious and objective risk of actual bias when a person with a personal stake in a particular case has a significant and disproportionate influence in placing the judge on the case by raising funds or directing the judge’s election campaign when the case was pending or imminent, which risk creates a probability of bias that threatened due process.
6. RATIONALE:
The Court identified additional instances, which require recusal where the “probability of actual bias” on the part of the judge is too high to be constitutionally tolerable. In this case, (1) Though not a bribe or