579 U.S. 1 (2016)
Terrance Williams was convicted of first-degree murder and sentenced to death in a Pennsylvania trial court in 1986 for the 1984 killing of Amos Norwood.1 During the prosecution, then-District Attorney Ronald Castille personally reviewed and approved the trial prosecutor's request to seek the death penalty against Williams by signing a sentencing memorandum.2
Over the ensuing 26 years, Williams's conviction and sentence were upheld on direct appeal as well as in multiple rounds of state postconviction proceedings and federal habeas review.3
In 2012, Williams filed a successive petition under the Pennsylvania Post Conviction Relief Act.4 The petition relied on newly obtained information from Williams's codefendant, Marc Draper, who revealed that the prosecution had suppressed evidence of a sexual relationship between Williams and Norwood and had instructed Draper to provide false testimony about the motive for the murder being robbery rather than the relationship.5
Following an evidentiary hearing, the PCRA court determined that the trial prosecutor had committed Brady violations by suppressing material exculpatory evidence.6 The court stayed Williams's execution and ordered a new sentencing hearing.7
The Commonwealth appealed to the Pennsylvania Supreme Court to vacate the stay.8 At that time, Ronald Castille was serving as Chief Justice of the Pennsylvania Supreme Court.9 Williams filed a motion seeking Castille's recusal based on his prior role in approving the death penalty request.10 Chief Justice Castille denied the recusal motion without explanation and joined the opinion that vacated the PCRA court's grant of relief and reinstated Williams's death sentence.11 Castille retired from the bench two weeks after the decision.12
Williams subsequently pursued federal habeas corpus relief, which the district court denied and the Third Circuit affirmed.13
Whether the Due Process Clause of the Fourteenth Amendment requires recusal when a judge had significant, personal involvement as a prosecutor in a critical decision regarding the defendant's case?14
The Due Process Clause of the Fourteenth Amendment requires an impartial judge. It prohibits a judge from serving in a case in which the judge earlier had significant, personal involvement as a prosecutor in a critical decision regarding the defendant's case. Such circumstances create an impermissible risk of actual bias under an objective standard.15
Yes. Chief Justice Castille's authorization to seek the death penalty against Williams amounted to significant, personal involvement in a critical trial decision. When the same case came before him as chief justice on the PCRA appeal seeking to reinstate the death sentence he had authorized, the objective risk of actual bias was too high to be constitutionally tolerable.16
The Due Process Clause required Chief Justice Castille to recuse himself from participating in Williams's case.17
Related opinions on this issue
Joined by Justice Alito
Chief Justice Roberts dissented from the majority's holding.18 He argued that the Due Process Clause did not require recusal in this case. The facts in In re Murchison differed because the judge there had adjudicated the same question based on the same facts he had considered as a grand juror.
In contrast, Chief Justice Castille had no previous knowledge of the contested facts at issue in Williams's habeas petition. He had not previously made any decision on the questions raised by that petition. Chief Justice Roberts would hold that the Due Process Clause did not require Chief Justice Castille's recusal.19
Justice Thomas dissented, contending that the majority mischaracterized the nature of the proceedings. Williams's postconviction petition was a separate civil matter, not a continuation of the criminal case. Historical practice and the Court's precedents do not require recusal of a former prosecutor in postconviction proceedings.
The Due Process Clause demands less in postconviction review than in criminal prosecutions. Perceived bias alone, without a direct financial interest or service as counsel in the same case, is not a constitutional violation. Justice Thomas emphasized that the postconviction petitioner has already been found guilty at a fair trial and has only a limited interest in postconviction relief.20
Whether an unconstitutional failure to recuse constitutes structural error that is not amenable to harmless-error review, regardless of whether the judge's vote was dispositive?21
An unconstitutional failure to recuse constitutes structural error that is not amenable to harmless-error review, regardless of whether the judge's vote was dispositive, because it affects the entire adjudicatory framework and undermines the appearance and reality of neutrality in a multimember court.22
Yes. Chief Justice Castille's participation affected the Pennsylvania Supreme Court's whole adjudicatory framework below when he denied recusal and joined the opinion reinstating the death sentence. Because appellate deliberations are confidential, it is neither possible nor productive to inquire whether the interested jurist influenced colleagues, and the appearance of bias demeans the integrity of the institution regardless of whether the vote was dispositive. Williams must therefore be granted an opportunity to present his claims to a court unburdened by any possible temptation not to hold the balance nice, clear and true between the State and the accused.23
The failure to recuse constituted structural error requiring that Williams receive relief.24