They were decided just seven months apart and are in some ways hard to reconcile. But there is a message in the combined holdings of *Caperton v. A.T. Massey Coal Co.* and *Citizens United v. Federal Election Commission*. It is that the Supreme Court views the justice system as specially vulnerable to the influence of money.
The *Caperton* decision, now thrown into sharp relief by *Citizens United*, has started a vigorous conversation about the meaning of fairness in adjudication, one to which this special issue of the *Arizona Law Review* on “Funding Justice” makes an important contribution.
The conversation reflected in these pages is necessary in part because it is not easy to divine a broad principle from *Caperton*, which said little about when the requirements of due process require judges to recuse themselves beyond holding that three million dollars in campaign spending is just too much money.