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Constitutional Law Keyed to Choper
Caperton v. Massey Coal Co.
Citation:
556 U.S. 868 (2009)Facts
In 2002, a West Virginia jury found Massey Coal liable for fraudulent misrepresentation, concealment, and tortious interference with contractual relations, awarding Caperton $50 million in damages. While Massey’s appeal was pending, Don Blankenship, Massey’s chairman and CEO, spent approximately $3 million to support Brent Benjamin’s campaign for the West Virginia Supreme Court of Appeals against incumbent Justice McGraw. This amount exceeded the total spent by Benjamin’s own campaign committee by 300% and constituted more than two-thirds of the total funds raised by the independent political organization supporting Benjamin. Benjamin won the election and subsequently refused Caperton’s three separate motions for recusal, claiming no actual bias existed. Justice Benjamin then participated in the appeal and twice voted with the majority in 3-2 decisions to reverse the $50 million verdict against Massey. Caperton argued that Justice Benjamin’s failure to recuse himself violated due process given the extraordinary campaign support from Blankenship.
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