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Case Overview

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The Supreme Court ruled in a 5–4 decision that the failure of a judge to recuse himself violated the Due Process Clause of the Fourteenth Amendment. In a majority opinion authored by Justice Kennedy, the Court emphasized that the probability of actual bias was too high to be constitutionally tolerable. 

Facts/Syllabus

In 1998, the president of Harman Mining Company filed a lawsuit against A.T. Massey Coal Co. alleging fraudulent misrepresentation and cancellation of a coal supply contract, resulting in Harman Mining going out of business. In 2002, a jury voted in favor of Harman Mining, awarding $50 million in damages.

While the case was pending appeal, Massey's CEO Don Blankenship spent approximately $3 million to support the election of Brent Benjamin to the West Virginia Supreme Court of Appeals, the very court that would hear his appeal. Benjamin won the election. Harman Mining requested that Benjamin recuse himself due to this apparent conflict of interest, but he refused and ultimately voted in the 3–2 majority to overturn the $50 million verdict.

Importance of Case

The Supreme Court established that in extraordinary situations where impartiality might reasonably be questioned, particularly involving significant campaign support by a litigant, judges must recuse themselves because the appearance and risk of bias could undermine public confidence in judicial impartiality.

 

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