The Supreme Court found that a judge previously involved in a capital case as a prosecutor should have recused himself during an appeal launched by the death row inmate.
Justices ruled Thursday, in a 5-3 vote, that then-Pennsylvania Supreme Court Chief Justice Ronald Castille violated the Due Process rights of Terrence Williams in 2012, when the jurist declined to withdraw from Williams’ challenge of his conviction. His death sentence was upheld by the state’s high court.
“A constitutionally intolerable probability of bias exists when the same person serves as both accuser and adjudicator in a case,” the majority noted. They remanded Williams’ case back to the Pennsylvania Supreme Court.
Williams, then 18 years old, was found guilty of the 1984 murder of Amos Norwood, 56, in Philadelphia. In 2012, Williams challenged his conviction because one of the prosecution’s witnesses came forward with new evidence.
Marc Draper had testified during the initial trial, saying he and Williams robbed and then beat Norwood to death. Later, he told Williams’ lawyers that their client had been sexually involved with Norwood “and that the relationship was the real motive for Norwood’s murder.”
“According to Draper, the Commonwealth [of Pennsylvania] had instructed him to give false testimony that Williams killed Norwood to rob him,” the majority opinion stated. “Draper also admitted he had received an undisclosed benefit in exchange for his testimony: the trial prosecutor had promised to write a letter to the state parole board on his behalf.”
During Williams’ trial, however, Draper only revealed to the jury that he made a deal with prosecutors to plead guilty “in exchange for truthful testimony.”
The Pennsylvania Court of Common Pleas found this to be a suppression of evidence, enough cause to stay Williams’ execution. The decision was immediately challenged by state prosecutors in an emergency petition to the Supreme Court.
When the lower court approved of Williams challenge, it ordered law enforcement and prosecutors to give his attorneys more evidence. In that discovery process, they learned that Castille, as a Philadelphia distract attorney, had signed off on approval to seek the death penalty in their client’s case.
Williams’ defense team asked Castille to recuse himself from the hearing, but he declined to do so without giving an explanation.
“Because Chief Justice Castille’s authorization to seek the death penalty against Williams amounts to significant, personal involvement in a critical trial decision, his failure to recuse from Williams’s case presented an unconstitutional risk of bias,” the Supreme Court stated Thursday.
Writing for the majority, Justice Anthony Kennedy wholeheartedly rejected Pennsylvania’s argument, that Castille’s involvement in the death penalty approval “amounted to a brief administrative act limited to ‘the time it takes to read a one-and-a-half-page memo.’”
“In this Court’s view, that characterization cannot be credited,” Kennedy stated. “The Court will not assume that then-District Attorney Castille treated so major a decision as a perfunctory task requiring little time, judgment, or reflection on his part.”
Joining Kennedy on the majority were the four liberal justices on the Court.
Though a conservative, Kennedy has cast crucial swing votes backing liberal decisions. Thursday’s 5-3 split marked the first time he joined Democrats this Supreme Court term, according to SCOTUSblog. The year-long session started last October.
Chief Justice John Roberts, authoring the dissent, stated that Due Process is only 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.”
“The majority opinion rests on proverb rather than precedent,” he wrote for the minority.
The Fifth and Fourteenth Amendments guarantee due process in the US Constitution.
