Williams v. Pennsylvania - 136 S. Ct. 1899 (2016)

Rule:

Under the Due Process Clause there is an impermissible risk of actual bias when a judge earlier had significant, personal involvement as a prosecutor in a critical decision regarding the defendant’s case.

Facts:

Petitioner Williams was convicted of the 1984 murder of Amos Norwood and sentenced to death. During the trial, the then-district attorney of Philadelphia, Ronald Castille, approved the trial prosecutor's request to seek the death penalty against Williams. Over the next 26 years, Williams's conviction and sentence were upheld on direct appeal, state postconviction review, and federal habeas review. In 2012, Williams filed a successive petition pursuant to Pennsylvania's Post Conviction Relief Act ("PCRA"), arguing that the prosecutor had obtained false testimony from his codefendant and suppressed material, exculpatory evidence in violation of Brady v. Maryland, 373 U. S. 83, 83 S. Ct. 1194, 10 L. Ed. 2d 215. Finding that the trial prosecutor had committed Brady violations, the PCRA court stayed Williams's execution and ordered a new sentencing hearing. The Commonwealth asked the Pennsylvania Supreme Court, whose chief justice was former District Attorney Castille, to vacate the stay. Williams filed a response, along with a motion asking Chief Justice Castille to recuse himself or, if he declined to do so, to refer the motion to the full court for decision. Without explanation, the chief justice denied Williams's motion for recusal and the request for its referral. He then joined the State Supreme Court opinion vacating the PCRA court's grant of penalty-phase relief and reinstating Williams's death sentence. Two weeks later, Chief Justice Castille retired from the bench. The United States Supreme Court granted William’s petition for certiorari.

Issue:

Did the justice’s denial of the petitioner’s recusal motion and his subsequent judicial participation violate the Due Process Clause of the Fourteenth Amendment?

Answer:

Yes.

Conclusion:

The Court held that Chief Justice Castille’s denial of the recusal motion and his subsequent judicial participation violated the Due Process Clause of the Fourteenth Amendment. According to the Court, under the Due Process Clause, there was an impermissible risk of actual bias when a judge earlier had significant, personal involvement as a prosecutor in a critical decision regarding a defendant's case. The Court applied an objective standard that required recusal when the likelihood of bias on the part of the judge was too high to be constitutionally tolerable. The Court held that a constitutionally intolerable probability of bias existed when the same person served as both accuser and adjudicator in a case. Because Chief Justice Castille’s authorization to seek the death penalty against Williams amounted to significant, personal involvement in a critical trial decision, his failure to recuse from William’s case presented an unconstitutional risk of bias, which therefore violated due process. The Court held that the justice's unconstitutional failure to recuse was not amenable to harmless error review even if the justice’s vote was not dispositive. Accordingly, the judgment was vacated and the case was remanded.