Term: 2015
Docket: 15-5040
Williams v. Pennsylvania
- Pro
15-5040 WILLIAMS V. PENNSYLVANIA DECISION BELOW: 105 A.3d 1234 CERT. GRANTED 10/1/2015 QUESTION PRESENTED: 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? LOWER COURT CASE NUMBER: 668 CAP, 669 CAP
In the case of Williams v. Pennsylvania, Terrance Williams challenged his death sentence on the grounds that one of the justices in his appeal had significant involvement in a prior prosecutorial decision regarding him. Justice Ronald Castille, who was part of the Supreme Court panel reviewing William's post-conviction proceedings, had previously served as District Attorney and approved seeking capital punishment against Williams during his initial trial. The U.S. Supreme Court ruled 5-3 that this constituted an unacceptable risk of bias and violated due process rights under the Fourteenth Amendment to have an impartial tribunal free from potential prejudice or conflict-of-interest situations. Therefore, it held that Judge Castille should have recused himself from participating in William's case review because he could not be expected to consider fairly whether he made errors when he sought death penalty for Williams years earlier as prosecutor.
In the dissenting opinion for Williams v. Pennsylvania, Chief Justice Roberts, joined by Justices Alito and Thomas, argued that there was no constitutional violation because former prosecutor Castille did not have a significant personal involvement in a critical trial decision. They contended that his authorization to seek the death penalty as district attorney was part of his administrative duties and did not constitute substantial involvement in the case. The dissent also emphasized that Castille had no direct participation or influence over any strategic decisions during Williams' trial or sentencing phase. Furthermore, they disagreed with the majority's new rule requiring recusal when a judge had prior involvement as a prosecutor in an earlier stage of the same case; arguing it lacked support from precedent and could lead to unnecessary disqualifications of judges who previously served as prosecutors.
