Supreme Court of the United States
Terrance Williams, Petitioner v. Pennsylvania.
June 9, 2016579 U.S. 1
Summary
The Supreme Court held that the Due Process Clause of the Fourteenth Amendment is violated when a judge who earlier had significant, personal involvement as a prosecutor in a critical decision in the defendant's case denies recusal and later participates in adjudication; former Philadelphia District Attorney Ronald Castille's authorization to seek the death penalty against Terrance Williams was such a critical decision. Because an unconstitutional failure to recuse is structural error 'not amenable' to harmless-error review even when the disqualified judge's vote on a multimember court was not dispositive, the Court vacated the Pennsylvania Supreme Court's judgment reinstating Williams's death sentence and remanded so his successive PCRA claims could be heard by an unbiased court. Chief Justice Roberts, joined by Justice Alito, dissented, arguing that In re Murchison does not extend to distinct postconviction questions Castille never considered as a prosecutor; Justice Thomas also dissented, contending that postconviction review is a new civil proceeding to which the narrower historical disqualification rules apply.
Holding
- Whether Chief Justice Castille's denial of the recusal motion and subsequent judicial participation violated the Due Process Clause given his earlier authorization of the death penalty as district attorney.. Yes. Under the Due Process Clause there is an impermissible risk of actual bias when a judge earlier had significant, personal involvement as a prosecutor in a critical decision regarding the defendant's case; Castille's authorization to seek the death penalty was such involvement, so due process compelled his recusal.
- Whether the due process violation is excusable as harmless error where the disqualified justice's vote was not necessary to the disposition on a multimember court.. No. An unconstitutional failure to recuse constitutes structural error 'not amenable' to harmless-error review, regardless of whether the judge's vote was dispositive.
Docket 15–5040.
Cited authorities
- Rule 2.11
- Rule 2.11(A)(6)(b)
- 42 Pa. Cons. Stat. §9541
- 28 U.S.C. §455
- 56 Yale L.J. 605
- 56 N.Y.U. L. Rev. 353