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FOURTHEENTH AMENDMENT

Williams v. Pennsylvania

Issues

Do the Eighth and Fourteenth Amendments require an appellate judge’s recusal in a capital punishment appeal when the judge, previously a district attorney, oversaw the office that prosecuted the same case?

 

In 1984, Terrance Williams was sentenced to death for the murder of Amos Norwood. After successfully receiving post-conviction sentencing relief in 2012, the Supreme Court of Pennsylvania reversed and reinstated Williams’ sentence. In this case, the U.S. Supreme Court will decide whether the Eighth and Fourteenth Amendments require the recusal of an appellate judge—here Pennsylvania Chief Justice Ronald Castille—from participation in a capital punishment appeal when the judge led the District Attorney’s Office that prosecuted the same case. Williams argues that due process compels recusal, given the risk of potential bias and partiality that may taint both the judge’s decision-making and the reviewing tribunal’s impartiality. However, Pennsylvania argues that Justice Castille’s recusal was not constitutionally required under the Court’s holding in Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (2009), nor was his presence on the Supreme Court of Pennsylvania in violation of the Eighth and Fourteenth Amendments. This case will impact an appellate judge’s ability to make discretionary determinations regarding his or her own recusal.

Questions as Framed for the Court by the Parties

  1. Whether 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. Whether 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?

On June 11, 1984, Terrance Williams and Marc Draper robbed and murdered Amos Norwood.  See Brief for Petitioner at 4.  The Philadelphia District Attorney’s Office, under the leadership of then-District Attorney Ronald Castille, prosecuted the defendants.  

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