Williams v. Pennsylvania
136 S. Ct. 1899, 195 L.Ed.2d 132 (2016)
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Rule of Law:
The Due Process Clause of the Fourteenth Amendment requires a judge to recuse from a case in which the judge previously had significant, personal involvement as a prosecutor in a critical decision regarding the defendant's case. Failure to do so constitutes a structural error.
Facts:
- In 1984, Terrance Williams murdered Amos Norwood.
- During Williams's trial, the prosecutor requested and received approval from the then-District Attorney, Ronald Castille, to seek the death penalty.
- Castille's approval consisted of a handwritten note on a prosecutor's memorandum stating, 'Approved to proceed on the death penalty.'
- Years later, a key witness, Marc Draper, alleged that he had informed prosecutors before the trial that Williams had been in a sexual relationship with the victim, Norwood, and that prosecutors had instructed him to provide false testimony about the motive being robbery.
- While campaigning for a judicial seat, Castille publicly stated that he had 'sent 45 people to death rows' during his tenure as district attorney.
Procedural Posture:
- Terrance Williams filed a successive petition under Pennsylvania's Post Conviction Relief Act (PCRA) in the Philadelphia Court of Common Pleas (the PCRA court).
- The PCRA court found the prosecution had suppressed material evidence, stayed Williams's execution, and ordered a new sentencing hearing.
- The Commonwealth filed an emergency application with the Supreme Court of Pennsylvania to vacate the stay.
- Williams filed a motion asking Chief Justice Ronald Castille to recuse himself due to his prior involvement as District Attorney.
- Chief Justice Castille denied the recusal motion.
- The Supreme Court of Pennsylvania, with Chief Justice Castille participating in the majority, vacated the PCRA court's order and reinstated Williams's death sentence.
- The U.S. Supreme Court granted Williams's petition for a writ of certiorari.
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Issue:
Does a judge's participation in a case, where that judge as a former prosecutor personally approved seeking the death penalty against the same defendant, violate the Due Process Clause of the Fourteenth Amendment?
Opinions:
Majority - Justice Kennedy
Yes. A judge's participation in a case where that judge, as a former prosecutor, personally approved seeking the death penalty against the same defendant violates the Due Process Clause. Due process guarantees an absence of actual bias and requires recusal when the objective likelihood of bias is 'too high to be constitutionally tolerable.' An unconstitutional potential for bias exists when the same person serves as both accuser and adjudicator, as a prosecutor who makes a critical decision is integral to the accusatory process. There is a risk the judge would be 'psychologically wedded' to his or her previous position and would unconsciously avoid the appearance of having erred. Castille's approval to seek the death penalty was a 'significant, personal involvement' in a 'critical' decision, not a mere administrative act. The failure to recuse is a structural error affecting the entire adjudicatory framework, which is not subject to harmless-error review.
Dissenting - Chief Justice Roberts
No. The judge's participation did not violate the Due Process Clause. The majority's holding rests on proverb rather than precedent and fails to overcome the presumption of judicial honesty and integrity. The key precedent, In re Murchison, is distinguishable because in that case the judge had prejudged the very same factual and legal issues he was later called upon to adjudicate. Here, Castille's prior decision to authorize the death penalty was entirely separate from the post-conviction issues before the Pennsylvania Supreme Court, which concerned prosecutorial misconduct and the timeliness of the petition. Castille had no prior knowledge of the facts underlying the post-conviction claims, and his ruling on them would not imply he had 'erred' in his original decision. While recusal may have been proper under state ethics codes, it was not constitutionally compelled.
Dissenting - Justice Thomas
No. The judge's participation did not violate the Due Process Clause because the majority fails to distinguish between a criminal proceeding and a post-conviction civil proceeding. Williams's conviction became final decades ago; the post-conviction action is a new, separate civil case with fewer procedural protections. Historically, due process required recusal for a direct pecuniary interest or for serving as counsel in the same case. Castille did not serve as prosecutor and judge in the same case because the post-conviction review is a distinct legal matter. The majority's decision is an unwarranted extension of Caperton's 'probability of bias' standard, which should not be applied so broadly to state post-conviction proceedings where states have more procedural flexibility.
Analysis:
This decision establishes a clear, objective constitutional rule for judicial recusal based on prior prosecutorial involvement. It holds that a judge's 'significant, personal involvement' in a 'critical' prosecutorial decision creates an unconstitutional risk of bias, mandating recusal under the Due Process Clause. By classifying the failure to recuse as a structural error, the Court ensures that the remedy is a new hearing, regardless of whether the biased judge's vote was decisive. This strengthens due process protections by prioritizing the appearance of impartiality and the institutional integrity of the judiciary over case-specific outcomes.
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