Williams v. Pennsylvania
On June 9, 2016, the U.S. Supreme Court ruled, 5-3, that death row prisoner Terry Williams’ constitutional rights were violated when former Pennsylvania Supreme Court Chief Justice Ronald Castille refused to recuse himself from consideration of Mr. Williams’ death penalty appeal. The Court remanded the case, Williams v. Pennsylvania, for consideration by a neutral, unbiased court (Click here for the opinion).
Chief Justice Castille was the elected District Attorney of Philadelphia through the trial, capital sentencing, and direct appeal proceedings in Mr. Williams’ case. As District Attorney, he personally approved the decision to pursue capital punishment against Mr. Williams. He later campaigned successfully for a seat on the Pennsylvania Supreme Court. While on the Pennsylvania Supreme Court, Chief Justice Castille voted to overturn the decision from the lower court which vacated Mr. Williams' death sentence. The lower court found that the Philadelphia District Attorney's office, under Chief Justice Castille's leadership, had withheld evidence that Mr. Williams’ victim had sexually abused him.
As Justice Anthony Kennedy wrote in the majority opinion, the due process guarantee that "no man can be a judge in his own case would have little substance if it did not disqualify a former prosecutor from sitting in judgment of a prosecution in which he or she had made a critical decision.” Justice Kennedy also found that the fact that former Chief Justice Castille’s vote was not the deciding vote on the multi-member panel of the Pennsylvania Supreme Court does not “lessen the unfairness.”
(1) In Caperton v. A.T. Massey Coal Co., 556 U.S. 868, 881 (2009), this Court held that due process requires an “objective” inquiry into judicial bias. The question presented is:
Are the Eighth and Fourteenth Amendments violated where the presiding Chief Justice of a state supreme court declines to recuse himself in a capital case where he had personally approved the decision to pursue capital punishment against Petitioner in his prior capacity as elected District Attorney and continued to head the District Attorney’s office that defended the death verdict on appeal; where, in his state supreme court election campaign, the Chief Justice expressed strong support for capital punishment, with reference to the number of defendants he had “sent” to death row, including Petitioner; and where he then, as Chief Justice, reviewed a ruling by the state post-conviction court that his office committed prosecutorial misconduct under Brady v. Maryland, 373 U.S. 83 (1963), when it prosecuted and sought death against Petitioner?
(2) In Aetna Life Insurance Co. v. Lavoie, 475 U.S. 813 (1986), this Court left open the question whether the Constitution is violated by the bias, appearance of bias, or potential bias of one member of a multimember tribunal where that member did not cast the deciding vote. The circuits and states remain split on that question. The question presented is:
Are the Eighth and Fourteenth Amendments violated by the participation of a potentially biased jurist on a multimember tribunal deciding a capital case, regardless of whether his vote is ultimately decisive?
Below are links to legal briefs and other relevant case documents in the matter of Williams v. Pennsylvania:
Amicus Briefs in Support of Petitioner in Williams v. Pennsylvania