Caperton v. Massey
In 2006, litigant Caperton filed a motion requesting that Justice Brent Benjamin of the Supreme Court of Appeals of West Virginia recuse himself from the appeal of the $50 million jury verdict in a contract dispute between two litigant mining companies. Justice Benjamin refused to recuse himself, even though the CEO of the lead defendant had spent $3 million supporting Justice Benjamin’s campaign for a seat on the court—more than 60% of the total amount spent to support his campaign—while preparing to appeal the verdict against his company. After winning election to the court, Justice Benjamin cast the deciding vote in the court’s 3-2 decision overturning that verdict. The U.S. Supreme Court granted Caperton’s cert petition on the question of whether Justice Benjamin’s failure to recuse himself from Massey’s appeal violated the Due Process Clause of the Fourteenth Amendment rights of Caperton. The U.S. Supreme Court held “that there is a serious risk of actual bias—based on objective and reasonable perceptions—when a person with a personal stake in a particular case had a significant and disproportionate influence in placing the judge on the case” and that recusal was required in this case.