In 1984, former Philadelphia District Attorney Ronald Castille successfully sought the death penalty for 18-year-old Terrance Williams, who was convicted of murdering a man named Amos Norwood. Within a week of Williams’ scheduled execution almost 30 years later, newly uncovered evidence caused the Philadelphia Court of Common Pleas to reverse Williams’ death sentence.
Prosecutors appealed this decision to the Pennsylvania Supreme Court, where Castille now presided as Chief Justice, and Williams’ death penalty was reinstated despite a motion filed by Williams’ attorneys requesting Castille’s recusal.
Following oral arguments in February, the U.S. Supreme Court reversed the Pennsylvania Supreme Court’s ruling in a 5-3 decision on June 9, 2016, citing due process concerns under the Fourteenth Amendment in Chief Justice Castille’s unwillingness to recuse himself from the case.
Justice Anthony Kennedy wrote the majority opinion, joined by the liberal justices of the Court, claiming that Castille should have stepped aside to avoid violating Williams’ Eighth and Fourteenth Amendment rights.
The due process guarantee that, “no man can be a judge in his own case,” he noted, “would have little substance if it did not disqualify a former prosecutor from sitting in judgment of a prosecution in which he or she had made a critical decision.”
The Court ordered the Pennsylvania Supreme Court to reconsider the appeal, and since Chief Justice Castille is now retired, the risk of bias is much less likely.
Joined by Justice Samuel Alito, Chief Justice John Roberts issued a dissenting opinion criticizing the Court for making a decision solely based on “proverb rather than precedent.”
He claimed that Chief Justice Castille did not have significant personal involvement in the case because the case at the Pennsylvania Supreme Court regarded prosecutorial misconduct, not the death penalty.
Justice Clarence Thomas also filed a dissenting opinion, in which he further pressed a distinction between Williams’ criminal proceedings issued 30 years ago and his post-conviction proceedings within the last few years.
Philadelphia Defense Attorney Amato Sanita commented, “In cases involving our Supreme Court in Pennsylvania, any such perception of bias from a particular Justice’s comments should be taken into consideration when deciding whether a recusal is in order. It is the only way to ensure an individual’s rights and liberties are protected.”
In essence, the Court has used a fairly broad legal argument citing fundamental Constitutional concerns to create a much narrower decision, since most states already use this type of judge-recusal practice to prevent bias.
However, it could be an important step in making recusal law a Constitutional right, preventing similar instances in the future.
