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Massey Coal Co., the Court held that the probability of actual bias on the part of a judge becomes constitutionally intolerable when a party before him is a person with a significant and disproportionate influence in placing the judge on the case, by raising funds or directing the judges election campaign when the case was pending or imminent. The obvious countervailing factor here is that the election in question was awash with expenditures from people on both sides of the cases before Karmeier, with more than $2 million reportedly having been spent by four plaintiffs lawyers and three plaintiffs law firms on negative TV ads and robo-call campaigns against Karmeier

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