Williams v. Pennsylvania
136 S. Ct. 1899
| SCOTUS | 2016Background
- Williams was convicted of first-degree murder and sentenced to death in 1984; his conviction and sentence survived direct and postconviction review for decades.
- In 2012, Williams filed a successive PCRA petition based on new information from Draper suggesting Brady violations and both suppression and misrepresentation at trial.
- The PCRA court found Brady violations, ordered production of undisclosed files, stayed Williams's execution, and ordered a new sentencing hearing.
- Chief Justice Castille, then Philadelphia DA who authorized seeking the death penalty in Williams's case, refused Williams's recusal motion and did not refer it to the full court.
- The Pennsylvania Supreme Court reinstated Williams's death sentence, vacating the PCRA court’s penalty-phase relief, after Castille's participation was challenged.
- The United States Supreme Court held that due process required Castille's recusal due to significant, personal involvement as a prosecutor in a critical decision, vacated the Pennsylvania court’s judgment, and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether recusal was required due to prior prosecutor involvement | Williams contends Castille's prior authorization to seek death created bias risk. | Castille asserts no disqualifying conflict in postconviction review; postconviction proceedings are separate. | Yes; due process required recusal due to significant, personal involvement. |
| Whether the recusal error is structural or harmless | The error is structural because appearance of neutrality was compromised. | If not dispositive, it could be harmless on review. | Structural error; not amenable to harmless-error analysis. |
| What relief Williams is entitled to | Remand for proceedings free of taint would cure due-process violation. | Relief may be limited; procedural posture is complex and past rulings differ. | Remand for proceedings on remanded terms consistent with due-process requirements. |
Key Cases Cited
- Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (U.S. 2009) (recusal when probability of actual bias is too high)
- In re Murchison, 349 U.S. 133 (U.S. 1955) (judge cannot act as accuser and judge in same case)
- Withrow v. Larkin, 421 U.S. 35 (U.S. 1975) (economic and psychological bias concerns in adjudication)
- Tumey v. Ohio, 273 U.S. 510 (U.S. 1927) (due process limits on judges with direct pecuniary interest)
- Aetna Life Ins. Co. v. Lavoie, 475 U.S. 813 (U.S. 1986) (outer boundaries of judicial disqualification)
- Puckett v. United States, 556 U.S. 129 (U.S. 2009) (harmless-error review of biased judge not applicable to certain recusal issues)