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

Brief Fact Summary.

Plaintiffs sued Defendants for fraudulent misrepresentation, concealment, and tortious interference with contractual relations in West Virginia state court.

Synopsis of Rule of Law.

The Due Process Clause of the Fourteenth Amendment requires judges to recuse themselves not only when they have a direct, personal, substantial, pecuniary interest in a case, but also when the facts and circumstances demonstrate the probability for actual bias.

Facts.

Hugh Caperton, Harman Development Corp., Harman Mining Corp., and Sovereign Coal Sales (Plaintiffs) sued A.T. Massey Coal Co., Inc. (Defendant) for fraudulent misrepresentation, concealment, and tortious interference with contractual relations in West Virginia state court.

Issue.

Was Justice Benjamin’s refusal to recuse himself from a case involving a significant contributor to his election a violation of the Fourteenth Amendment?

Held.

Yes, Justice Benjamin’s refusal to recuse himself from the case was a violation of the Fourteenth Amendment. The decision is reversed and remanded.

Dissent.

Justice Roberts

Justice Roberts critiqued the Court’s rule for requiring recusal on the “probability of bias,” arguing that the rule was too vague and created too many situations where a judge would need to be recused. To demonstrate this, Justice Roberts listed forty questions raised when applying the Court’s rule.

Justice Scalia

Justice Scalia agreed with Justice Roberts that the Court’s decision would create confusion. He argued that the decision would erode public confidence in the judicial system.

Discussion.

The Court determined that the Fourteenth Amendment requires recusal whether or not actual bias exists or can be proven. Here, Justice Benjamin should have recused himself because the facts showed a high probability of actual bias rising to an unconstitutional level. The important facts included the significant amount of money the Defendant’s CEO contributed and the temporal relationship between the contribution, election, and appeal.