In Caperton v. A.T. Massey Coal Co. (2009) U.S. 173 L.Ed.2d 1208, a West Virginia appellate court justice refused to recuse himself, despite multiple requests that he do so, in an appeal of a $ 50 million damage award against a company in which the largest individual contributor to the justice's election campaign was the chairman, chief executive officer, and president. The Supreme Court, in holding recusal was required, reviewed its precedent on the issue of bias, all of which concerned either actual pecuniary interest or contempt of court citations. The Supreme Court held that actual bias is not the pertinent inquiry because "the Due Process Clause of the Fourteenth Amendment has been implemented by objective standards that do not require proof of actual bias. In defining these standards, the Court has asked whether, 'under a realistic appraisal of psychological tendencies and human weakness,' the interest 'poses such a risk of actual bias or prejudgment that the practice must be forbidden if the guarantee of due process is to be adequately implemented.' " (Caperton, supra, 129 S.Ct. at p. 2263.) The Supreme Court concluded that whether bias rises to the constitutionally impermissible level is grounded in the "maxim that 'no man is allowed to be a judge in his own cause; because his interest would certainly bias his judgment, and, not improbably, corrupt his integrity.'" To determine whether bias meets the objective standard due process requires, "the Court has asked whether, 'under a realistic appraisal of psychological tendencies and human weakness,' the interest 'poses such a risk of actual bias or prejudgment that the practice must be forbidden if the guarantee of due process is to be adequately implemented.'" Id. at 883-84. Under that high standard, the Court has found judicial recusal constitutionally required only in "rare instances." Id. at 890. For example, when the judge had a "financial interest in the outcome of a case" or "in the criminal contempt context, where a judge had no pecuniary interest in the case but was challenged because of a conflict arising from his participation in an earlier proceeding" that suggested he had a strong interest in the outcome. Id. at 876-81. To this short list, the Court added those cases in which "a person with a personal stake in a particular case had a significant and disproportionate influence in placing the judge on the case by raising funds or directing the judge's election campaign when the case was pending or imminent." Id. at 884. As the Court pointed out, these types of cases "deal with extreme facts that create an unconstitutional probability of bias." Id. at 887.