U.S. Supreme Court Rules a Former Prosecutor, who Later Became a Judge, Cannot Rule on Defendant’s Appeal

In an opinion that should have been obvious, the United States Supreme Court ruled this week that a state supreme court justice should not have considered the appeal of a defendant he had previously prosecuted.  The name of the case is Williams v. Pennsylvania.

In 1984, when he was 18 years old, the defendant and his codefendant brutally beat a 56-year-old man to death in Philadelphia.  An assistant district attorney asked for permission from her boss – District Attorney Ronald Castille – to seek the death penalty against the defendant.  District Attorney Castille personally approved the decision to ask for the death penalty.  During the trial, the assistant district attorney convinced the jury to impose the death penalty.  More than two decades later, the codefendant asserted, for the first time, that prosecutors asked him to give false testimony at the defendant’s trial.  The codefendant also said the trial prosecutor had promised to write a letter of support when the codefendant came up for parole (a promise that had never been disclosed to the defendant, as required by the law).  The defendant filed a petition for relief in the trial court.  Following an evidentiary hearing, the trial court concluded the District Attorney’s Office – then led by Ronald Castille – had committed misconduct that required the defendant to receive a new sentencing hearing.  The District Attorney’s Office appealed to the Pennsylvania Supreme Court.  The Pennsylvania Supreme Court had a chief justice named… Ronald Castille.  The same Ronald Castille who had previously been the District Attorney and authorized his assistant to seek the death penalty against the defendant.

Naturally, the defendant filed a motion for Chief Justice Castille to recuse himself from considering the case.  Castille refused to recuse himself and then voted with a majority of his colleagues to reverse the trial court and reinstate the defendant’s death penalty.  Castille wrote an opinion criticizing the defense attorneys for actually trying to get their client’s death penalty overturned.  Two weeks after the defendant’s case was decided by the Pennsylvania Supreme Court, Castille retired.

The defendant appealed, arguing that Castille had violated his due process rights by acting as both accuser and judge in his case.  In a no-brainer of a decision, the United States Supreme Court ruled that the Due Process Clause of the Fourteenth Amendment prohibits a prosecutor, who played a critical role in a defendant’s case, from later judging the case.  The Court pointed out that a judge who formerly prosecuted a defendant probably cannot set aside his or her personal interest in the case.  Obviously, Castille’s decision to seek the death penalty was significant.  The Court pointed out that Castille bragged about sending “45 people to death rows” when he was running his campaign for the Pennsylvania Supreme Court.  As a result, the defendant is entitled to a new sentencing hearing.

The only surprising aspect of this case is that three justices dissented.  They argued, essentially, that the defendant has appealed a bunch of times, and a long time has passed since Castille’s decision, and Castille wasn’t really involved all that deeply in the case, and so the defendant was not entitled to relief.   It’s an absurd conclusion, and luckily is didn’t carry the day.