A divided U.S. Supreme Court on Thursday said former Pennsylvania Supreme Court chief justice Ron Castille violated the Constitution's Due Process Clause when he didn’t recuse himself from the death penalty appeals case of Terrance Williams.
On February 29, 2016, the full U.S. Supreme Court heard arguments in Williams v. Pennsylvania. The question before the Court was if a judge or a member of a public tribunal should be disqualified – even if that person’s vote in a decision didn’t affect the final outcome- based on a perceived conflict of interest.
Link: Read Full Decision
“Chief Justice Castille’s denial of the recusal motion and his subsequent judicial participation violated the Due Process Clause of the Fourteenth Amendment,” said Justice Anthony Kennedy in his majority opinion. Williams' death-penalty decision was vacated and sent back to the Commonwealth for a new penalty hearing.
“Where a judge has had an earlier significant, personal involvement as a prosecutor in a critical decision in the defendant’s case, the risk of actual bias in the judicial proceeding rises to an unconstitutional level,” Kennedy concluded.
Chief Justice John Roberts wrote a dissent in the 5-3 decision, joined by Justice Samuel Alito. Roberts argued that the majority decision wasn’t based on precedent. “The Due Process Clause is violated when a judge adjudicates the same question—based on the same facts—that he had already considered as a grand juror in the same case,” Roberts said, adding that the state, and not the Supreme Court, should decide if Castille needed to recuse himself from the appeals case.
Justice Clarence Thomas also dissented. “It is a case about the due process rights of the already convicted. Whatever those rights might be, they do not include policing alleged violations of state codes of judicial ethics in post-conviction proceedings.”
In October 2015, Williams saw the Supreme Court accepted an appeal on Eighth and 14thAmendment ground in an appeals process that goes back to 2012. At the time, Williams’ defense wanted then-Pennsylvania Supreme Court chief justice Castille recused from his appeals case, since Castille had been the Philadelphia district attorney when Williams was convicted in 1986 for killing another Philadelphia man, Amos Norwood.
In 2012, Castille voted with four other Pennsylvania supreme court justices, in a unanimous decision, to overturn a lower court state ruling that found Williams should have a new penalty phase in his murder trial and that his execution order should be stayed. Before that ruling, Castille declined to recuse himself from deliberations.
Williams’ attorneys wanted answers from the United States Supreme Court related to two prior decisions. First, in a 2009 decision called Caperton v. A.T. Massey Coal Co., the Supreme Court said the West Virginia Supreme Court violated the concept of constitutional due process when a judge who cast a deciding vote had taken $3 million in political contributions from a party in the case. (Justice Anthony Kennedy also wrote the Caperton opinion.)
The attorneys also cited a case from 1986, Aetna Life Insurance v. Lavoie, where an Alabama judge had voted in a health insurance case after he had filed several personal legal actions in insurance cases.
The Williams team claimed that Castille’s decision to ask for the death penalty for Williams, while he was Philadelphia district attorney, along with Castille’s judicial role in considering allegations of misconduct of his prior district attorney’s office, are key factors in the appeal.
In its brief, the Philadelphia District Attorney’s office said the case should be denied because Williams’ claims that he was constitutionally entitled to Castille’s recusal were without merit and not applicable for review. In 2014, Castille retired from the Pennsylvania supreme court after reaching a mandatory retirement age.
