LOCATION: Supreme Court of Pennsylvania
DOCKET NO.: 15-5040
DECIDED BY: Roberts Court (2016- )
LOWER COURT: Supreme Court of Pennsylvania
CITATION: 579 US (2016)
GRANTED: Oct 01, 2015
ARGUED: Feb 29, 2016
DECIDED: Jun 09, 2016
Ronald Eisenberg - for the respondent
Stuart B. Lev - for the petitioner
Facts of the case
Terrance Williams was convicted and sentenced to death for the robbery and murder of Amos Norwood. The Supreme Court affirmed Williams’ conviction and sentence, and he filed three petitions under the Post-Conviction Relief Act, all of which were denied and the denials affirmed by the Pennsylvania Supreme Court. Williams also petitioned for federal habeas relief, which was denied. On his fourth petition for relief under the Post-Conviction Relief Act, the state court determined that Williams had sufficiently demonstrated that there was governmental interference in his trial and granted the relief. The Pennsylvania Supreme Court reversed the lower court’s decision and lifted the stay of execution.
The Chief Justice of the Pennsylvania Supreme Court at that point was Ronald Castille, who had been the District Attorney for Philadelphia throughout Williams’ trial, sentencing, and appeal, and who had personally authorized his office to seek the death penalty in this case. Prior to having his case heard by the Pennsylvania Supreme Court, Williams moved to have Chief Justice Castille recuse himself from this case. Chief Justice Castille refused to do so and ultimately joined the opinion that reversed the lower court’s grant of habeas relief and lifted the stay of execution.
Are the Eighth and Fourteenth Amendments violated when a state supreme court justice declines to recuse himself from a capital case in which he was the district attorney who approved the decision to seek the death penalty?
Are the Eighth and Fourteenth Amendments violated by the participation of a potentially biased jurist in a multi-member tribunal in a capital case, regardless of whether that jurist’s vote is ultimately decisive?
Media for Williams v. PennsylvaniaAudio Transcription for Oral Argument - February 29, 2016 in Williams v. Pennsylvania
Audio Transcription for Opinion Announcement - June 09, 2016 in Williams v. Pennsylvania
John G. Roberts, Jr.:
Justice Kennedy has the opinion of the Court in case 15-5040, Williams versus Pennsylvania.
Anthony M. Kennedy:
In 1986 the petitioner Terrance Williams was convicted of murder and sentenced to death in Pennsylvania.
The district attorney of Philadelphia whose office prosecuted the case and obtained the death sentence was Ronald Castille, as District Attorney Castille personally approved the prosecutor's request to seek the death penalty against Williams.
In 2012, Williams petitioned for state post-conviction relief.
He argued that the prosecution had suppressed exculpatory evidence and after an evidentiary hearing the state court granted relief to Williams.
It stayed his execution and ordered a new sentencing hearing.
Seeking to vacate those orders, the Commonwealth submitted an emergency application to the Pennsylvania Supreme Court.
By this time, and it was now close to three decades after Williams was tried and sentenced, Castille the former district attorney had been elected to a seat on the State Supreme Court and he was serving as its Chief Justice.
William filed a response to the Commonwealth's application.
He also filed a motion requesting Justice Castille to recuse himself or if he declined to do so to refer the recusal motion to the full court for decision.
Without explanation, the Chief Justice denied Williams’ motion for recusal.
Chief Justice Castille then joined the Pennsylvania Supreme Court's decision, vacating the grant of penalty-phase relief and reinstating Williams's death sentence.
Chief Justice Castille also filed a separate concurrence.
Among other points he denounced what he perceived as the obstructionist, anti-death penalty agenda of the attorneys representing Williams.
This Court granted certiorari to resolve where the Chief Justice Castille's denial of the recusal motion and his ensuing judicial participation violated of the Due Process Clause of the Fourteenth Amendment.
The Court's due process precedents do not set forth a specific test governing recusal when a judge, as here, had prior involvement in a case as a prosecutor.
The principles on which these precedents rest, however dictate the rule that controls this case.
The Court now holds that under the Due Process Clause there is an impermissible risk of actual bias when a judge had an earlier significant personal involvement as a prosecutor in a critical decision regarding the defendant's case.
To avoid inquiries as to whether a judge harbors an actual bias, the Court applies an objective standard.
The question is whether there is an impermissible risk of actual bias and under this test an unconstitutional potential for bias does exist when the same person serves as both accuser and adjudicator in a case.
No attorney is more integral to the accusatory process than a prosecutor who participates in a major adversary decision.
When a judge has serviced as an advocate for the state in a very case the court is then asked to adjudicate, a serious question arises as to whether the judge even with the most diligent effort could set aside any personal interest in the outcome.
This leads to the question whether Chief Justice Castille's authorization to seek the death penalty against Williams amounted to a significant personal involvement in the critical decision.
The Court now concludes that it was a significant personal involvement.
As a result Chief Justice Castille's failure to recuse in William's case presented an unconstitutional risk of bias.
There can be no doubt that the decision to pursue the death penalty is a critical choice in the adversary process.
Whether to ask a jury to end the defendant's life is one of the most serious discretionary decisions a prosecutor can be called upon to make nor is there is any doubt that Chief Justice Castille had a significant role in this decision.
Pennsylvania then argues that because Castille acted as one member of the multimember court that his vote was not necessarily decisive, but for reasons explained in the Court's opinion, the Court says, that failure to recuse cannot be deemed harmless even when the judge is on a multimember court.
For these and other reasons set forth in the opinion the judgment of the Supreme Court of Pennsylvania is vacated.
The case is remanded for further proceedings not inconsistent with this opinion.