Saturday, April 13, 2013

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

Caperton v. A.T.Massey Coal Co., Inc. case brief summary
556 U.S. 868 (2009)

Certiorari was granted to review a Supreme Court of Appeals of West Virginia decision that reversed a trial court judgment in favor of petitioners, a coal company and subsidiaries, against respondent corporation, on the question of whether the Fourteenth Amendment was violated when one of the majority justices refused to recuse himself due to receiving large campaign contributions from, and through the efforts of, the corporation's principal.

OVERVIEW: The principal contributed $ 3 million to replace the incumbent with the judge in question. His contributions eclipsed the total amount spent by all other supporters of the judge and exceeded by 300% the amount spent by the judge's campaign committee. Petitioners alleged the principal spent $ 1 million more than the total amount spent by both candidates' committees combined.

Whether the principal's contributions were a necessary and sufficient cause of the victory was not the proper inquiry. The principal's contributions--in comparison--had a significant and disproportionate influence on the election. The risk that it engendered actual bias was sufficiently substantial that it had to be forbidden to adequately implement the guarantee of due process. Due to timing, it was reasonably foreseeable, when the contributions were made, that the pending case would be before the newly elected justice. It became at once apparent that, absent recusal, he would review a judgment that cost his biggest donor's company $ 50 million. There was a serious, objective risk of actual bias that required recusal. On those extreme facts, the probability of actual bias rose to an unconstitutional level.

HOLDING: The decision of the Supreme Court of Appeals of West Virginia decision was reversed and the case was remanded. 5-4 Decision; 2 Dissents.

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