Williams v. Pennsylvania

136 S.Ct. 1899 (2016)

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Nature of the Case

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Facts

Williams (D) turned 18, and he murdered 56-year-old Amos Norwood. Pennsylvania (P) presented evidence that D and a friend, Marc Draper, had been standing on a street corner when Norwood drove by. D and Draper requested a ride home from Norwood, who agreed. Draper then gave Norwood false directions that led him to drive toward a cemetery. D and Draper ordered Norwood out of the car and into the cemetery. There, the two men tied Norwood in his own clothes and beat him to death. Testifying for the Commonwealth, Draper suggested that robbery was the motive for the crime. D took the stand in his own defense, stating that he was not involved in the crime and did not know the victim. The prosecutor requested permission to seek the death penalty against D. The then-district attorney of Philadelphia, Ronald Castille, wrote this note at the bottom of the document: “Approved to proceed on the death penalty.” D had a significant history of violent felony convictions. That criminal history included a previous conviction for a murder he had committed at age 17. The jury found no mitigating circumstances and sentenced D to death. Over a period of 26 years, D’s conviction and sentence were upheld on direct appeal, state post-conviction review, and federal habeas review. D discovered new evidence about the deal made with Draper and once again sought post-conviction relief. The court ordered the district attorney’s office to produce the previously undisclosed files of the prosecutor and police. These documents included the trial prosecutor’s sentencing memorandum, bearing then-District Attorney Castille’s authorization to pursue the death penalty. The court found that the trial prosecutor had suppressed material, exculpatory evidence in violation of Brady v. Maryland. Since the trial, Castille had been elected to a seat on the State Supreme Court and was serving as its chief justice. D filed a motion asking Chief Justice Castille to recuse himself or if he declined to do so, to refer the recusal motion to the full court for decision. Chief Justice Castille denied the motion for recusal and the request for its referral. The State Supreme Court then vacated the court’s order granting penalty-phase relief and reinstated D’s death sentence. The Supreme Court granted certiorari.