Conflict of interest is a good start....
"Critics have maintained that Justice Thomas should recuse himself from participating in cases that touch on issues his wife has publicly spoken about, even campaigned about. In January, for instance, the Supreme Court rejected Trump's effort to block a congressional subpoena for White House records related to the events surrounding the certification of the 2020 presidential election, and the Jan. 6 riot. The vote was 8-to-1, with Justice Thomas the lone dissenter"
