Williams v. Pennsylvania

There is an impermissible risk of bias, in violation of the Fourteenth Amendment Due Process Clause, when a judge’s prior involvement in a case as the prosecutor is significant, personal, and related to a critical decision.

Petitioner was convicted of murder in 1984. Due to aggravating factors, the prosecutor submitted a memo to her supervisor, the District Attorney, for permission to seek the death penalty. The request was granted and ultimately Petitioner was sentenced to death. In 2012, the execution was stayed by the Philadelphia Court of Common Pleas (“PCRA Court”), after it determined prosecutorial misconduct occurred at trial. On appeal to the Pennsylvania Supreme Court, the PCRA Court’s decision was reversed. The District Attorney that previously granted the prosecutor’s request to seek the death penalty was the sitting Chief Justice of the Pennsylvania Supreme Court and filed a concurring opinion in the reversal. The Chief Justice had also denied a motion for recusal filed by Petitioner. On appeal to the United States Supreme Court, Petitioner argued that the Chief Justice’s conduct violated the Fourteenth Amendment's Due Process Clause, because he acted as both the accuser and the judge against him. The Court reasoned that “actual bias” on the part of the judge is reviewed under an objective standard. The Court noted that the same person prosecuting a case cannot adjudicate his or her own case. The Court determined that a prosecutor risks becoming “psychologically wedded” to the case if he or she is involved in a critical decision during the case. Because the Chief Justice’s role was significant and personal, and the decision to seek the death penalty was critical in Petitioner's prosecution, the Court held that there was an impermissible risk of actual bias in Petitioner's case. The Court granted Petitioner the opportunity to have his case presented to a court unburdened by any possible bias. VACATED and REMANDED.