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Caperton v. A.T. Massey Coal Co., Inc.
United States Supreme Court
556 US 868 (2009)
Hugh Caperton and others (collectively, Caperton) (plaintiffs) were awarded $50 million in an action against A.T. Massey Coal Company (Massey) in West Virginia state court. West Virginia held its 2004 judicial elections after the verdict in the case but before Massey filed an appeal. Massey’s chairman, chief executive officer, and president, Don Blankenship, knew that the West Virginia Supreme Court of Appeals would hear the appeal in the case and decided to support the campaign of Brent Benjamin, an attorney who was running to unseat one of the supreme court justices up for reelection. Blankenship donated $1,000 to Benjamin’s campaign, donated $2.5 million to an organization that supported Benjamin, and spent $500,000 on mailings and advertisements supporting Benjamin. The $3 million Blankenship contributed to Benjamin’s campaign was three times more than Benjamin’s own campaign committee spent on the election and more than the total amount spent by all of Benjamin’s other supporters combined. Benjamin won the election by fewer than 50,000 votes. Caperton sought to disqualify Benjamin from hearing Massey’s appeal, but Benjamin denied the motion. The supreme court then reversed the trial court’s judgment in a 3-2 decision, with Benjamin in the majority. On rehearing, Benjamin again refused to recuse himself, and the supreme court again reversed the trial court’s judgment. Caperton sought review in the United States Supreme Court, arguing that Benjamin’s failure to recuse violated the Due Process Clause of the Fourteenth Amendment.
Rule of Law
Holding and Reasoning (Kennedy, J.)
Dissent (Roberts, C.J.)
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