Caperton v. A.T. Massey Coal Co.
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| Caperton v. A.T. Massey Coal Co. | |
| Reference: 556 U.S. 868 | |
| Term: 2008 | |
| Important Dates | |
| Argued: March 3, 2009 Decided: June 8, 2009 | |
| Outcome | |
| Supreme Court of Appeals of West Virginia reversed and remanded | |
| Majority | |
| Anthony Kennedy • John Paul Stevens • David Souter • Ruth Bader Ginsburg • Stephen Breyer | |
| Dissenting | |
| Chief Justice John Roberts • Antonin Scalia • Clarence Thomas • Samuel Alito | |
Caperton v. A.T. Massey Coal Co. is a 2009 United States Supreme Court case in which the court held that the 14th Amendment Due Process Clause requires judges to recuse themselves from cases that represent a probability of bias.[1][2] The case involved Justice Brent Benjamin of the Supreme Court of Appeals of West Virginia refusing to recuse himself from a case involving a major donor to his election campaign. The range of conflicts of interest that require judges to recuse themselves expanded following the U.S. Supreme Court's ruling.
Why it matters: The ruling expanded the application of the Due Process Clause in judicial recusal cases to instances where a probability of bias exists.[1]
Background
| Administrative State |
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| Read more about the administrative state on Ballotpedia. |
A West Virginia jury held A.T. Massey Coal Co. (Massey) and its affiliates "liable for fraudulent misrepresentation, concealment, and tortious interference with existing contractual relations" and awarded Hugh Caperton and other petitioners $50 million in compensatory damages in August 2002. The state trial court denied Massey's attempts to challenge the verdict in June of 2004.[1]
Before appealing the verdict further, Massey CEO Don Blankenship supported Brent Benjamin's campaign to join the Supreme Court of Appeals of West Virginia in the 2004 elections. Blankenship donated the maximum amount to Benjamin's campaign committee and an additional $2.5 million to an outside 527 group that supported Benjamin, over two-thirds of the total funds raised by the group. Moreover, Blankenship spent over $500,000 on direct mailings, letters, television and newspaper ads to support Benjamin. Benjamin won the judicial election and Caperton argued that Blankenship spent one million dollars more than the campaign committees of both candidates in the race combined.[1]
Caperton moved to disqualify the newly-elected Benjamin before Massey appealed to West Virginia's highest court. Benjamin denied Caperton's motion and Massey filed a petition to challenge the jury verdict in December 2006. In November 2007, the Supreme Court of Appeals of West Virginia ruled in favor of Massey Coal, reversing the $50 million award from the county court. Later, photos surfaced of Justice Spike Maynard and Massey chief Don Blankenship on vacation in Monaco. The two said they were only vacationing at the same place at the same time, and Maynard provided documentation to show he paid his own way. Still, the justices voted unanimously to rehear Caperton's case.[1]
Maynard voluntarily recused himself from all Massey cases, and Caperton demanded Justice Brent Benjamin also step down. Benjamin refused and the court again ruled in favor of Massey Coal in April 2008. Four months later, Justice Benjamin filed a concurring opinion defending his decision not to recuse himself. A month before Benjamin published his concurring opinion, Caperton appealed to the United States Supreme Court.[4][1]
Oral argument
Oral arguments were held on March 3, 2009. The case was decided on June 8, 2009.[1]
Decision
The U.S. Supreme Court decided to reverse and remand the lower court's ruling with a five to four vote. The majority opinion was written by Justice Anthony Kennedy and joined by John Paul Stevens, David Souter, Ruth Bader Ginsburg and Stephen Breyer. Chief Justice John Roberts wrote a dissenting opinion joined by Justices Antonin Scalia, Clarence Thomas and Samuel Alito. Justice Scalia wrote a separate dissenting opinion.[1]
Opinions
Opinion of the court
Writing for the majority, Justice Anthony Kennedy applied precedent from the 1975 case Withrow v. Larkin to argue that objective standards of due process required West Virginia Justice Benjamin to recuse himself from the Massey Coal case. He quoted Withrow saying that there are circumstances "in which experience teaches that the probability of actual bias on the part of the judge or decisionmaker is too high to be constitutionally tolerable." He acknowledged that the case arose out of extraordinary circumstances, but said the decision would not have disruptive effects because most recusal cases do not raise Constitutional questions.[1]
| “ | The temporal relationship between the campaign contributions, the justice’s election, and the pendency of the case is also critical. It was reasonably foreseeable, when the campaign contributions were made, that the pending case would be before the newly elected justice. The $50 million adverse jury verdict had been entered before the election, and the Supreme Court of Appeals was the next step once the state trial court dealt with post-trial motions. So it became at once apparent that, absent recusal, Justice Benjamin would review a judgment that cost his biggest donor’s company $50 million. Although there is no allegation of a quid pro quo agreement, the fact remains that Blankenship’s extraordinary contributions were made at a time when he had a vested stake in the outcome. Just as no man is allowed to be a judge in his own cause, similar fears of bias can arise when—without the consent of the other parties—a man chooses the judge in his own cause. And applying this principle to the judicial election process, there was here a serious, objective risk of actual bias that required Justice Benjamin’s recusal.
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Dissenting opinions
Chief Justice Roberts disagreed with holding that a probability of bias violated the Due Process Clause because that probability cannot be defined in a limited way. Without clear guidance about when the Constitution requires judges to recuse themselves, Roberts predicted that more people would accuse judges of being biased. He argued that the Due Process Clause only requires judicial recusal if the judge has a financial stake in the outcome of a case or if the judge presides over a criminal contempt case resulting from a defendant's hostility toward the same judge.
After introducing his argument, Roberts listed 40 separate questions that he believed courts would have to answer when considering whether judges have to recuse themselves under the probability of bias standard. In addition, he argued that using extreme cases to change established precedent creates bad law. In this case, Roberts predicted that the ruling would undermine the judicial system by allowing more challenges to its integrity.[1]
Justice Scalia wrote a separate dissenting opinion saying that the ruling will create vast uncertainty about a point of law that can be raised in any cases arising in states with judicial elections. He suggests that using the Constitution to try and correct the perceived wrong in this case will do more harm than good.[1]
See also
- Don Blankenship
- Brent Benjamin
- Supreme Court of the United States
- Supreme Court of Appeals of West Virginia
- Ballotpedia's administrative state coverage
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.00 1.01 1.02 1.03 1.04 1.05 1.06 1.07 1.08 1.09 1.10 1.11 JUSTIA, "Caperton v. A. T. Massey Coal Co., 556 U.S. 868 (2009)" accessed September 11, 2018
- ↑ Oyez, "Caperton v. A.T. Massey Coal Co.," accessed September 11, 2018
- ↑ SCOTUSblog, "Caperton v. A.T. Massey Coal Company, Inc., et al.," accessed September 11, 2018
- ↑ West Virginia Record, "Benjamin concurs, but does so much more," July 28, 2008
- ↑ Internal citations and quotations have been omitted
- ↑ Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
