Williams v Pennsylvania (2016) was brought to the Supreme Court by Williams who was found guilty of murder back in 1984 and sentenced to death because he claimed that the prosecution not only utilized false testimony but withheld evidence that could have led to his exoneration (Supreme Court, 2016). I found this particular case interesting due to its conclusion where the petitioner was ultimately denied his appeal even after his allegations were proven by the PCRA (Supreme Court, 2016) which just goes to show how even if the filer was in the right, the law still refused to rescue him from the death penalty. Clearly this was a direct violation of Williams’ right to due process under the Fourteenth Amendment of the Constitution for one of the judges on the court had a personal tie to the case (Supreme Court, 2016) thus suggesting a conflict of interest that should have been addressed before the court made their decision. This paper will provide an in-depth analysis of this case as it looks at how not only due process was ignored but the ruling found in Brady v Maryland as well.
In Brady v Maryland, the prosecution had also been guilty of breaching due process by withholding testimony that would work in the defendant’s favor but while the prosecutor in charge of the Williams case was not penalized, the one working on the Brady trial was (Kurcias, 2000). Kurcias goes on to note how “the Court in Brady held that a prosecutor commits a Due Process violation, requiring reversal of a conviction, when it is shown that the prosecutor withheld favorable, material evidence” (2000, p.1205). In other words the Court had found that any prosecutor who withholds important evidence should be held liable while the case they were working on should be reviewed which obviously did not happen with Williams appeal thus making one wonder how effective this ruling truly is and how many people are currently serving sentences they did not deserve. Perhaps there should be a review of said cases from a party that is not the Supreme Court to judge how fair their rulings truly are.
Originally the Due Process Clause only referred to protecting the people from unfair state or federal action but has been gradually expanded by the Supreme Court to encompass aspects of society such as the economy that is not covered by the Constitution (Strauss, 2016). Eventually due process became known as the clause focused on making sure procedures of any kind are properly carried out but while the Court would like the public to believe they expanded their jurisdiction so that they would be treated fairly under the law, there are those who claim that the Court is abusing due process to further their own interests. No doubt said critics would mention Williams’ situation as proof that even after the Due Process clause’s area of authority has been repeatedly broaden, there are still those who are refused this right due to the simple fact that one of the justices had a conflict of interest since they worked on the original case before being appointed to the Supreme Court. This is precisely why I suggested that an outside neutral party should review due process and the Court’s utilization of it to see if it is abusing this essential human right.
Accomplice liability can be related to Williams’ case in the sense that the prosecutor had to prove Williams was Draper’s accomplice which Williams’ denied, “Williams took the stand in his own defense, statingnot involved in the crimedid not know the victim” (Supreme Court, 2016, p.15). In order to prove Williams did commit murder then, the prosecution and the Court would have had to prove without a doubt that he worked with Draper with actual physical evidence when instead the prosecution withheld crucial testimony that could have led to his him being proven innocent. There are several ways to determine if he was guilty of accomplice or complicity liability that should have been examined such as they purchased the murder weapon before giving it to the killer knowing full well they were about to commit a crime which can be found in receipts and phone conversations between the accused before sentencing him to death.
Another element which should have been determined is actus reus where the defendant is found guilty without a doubt as the prosecution proves they committed the crime as well as why the crime took place in the first place. Actus reus often coincides with mens reus where the prosecution not only has to provide actual physical evidence but mental evidence of the defendant possessing a criminal mind which can be tricky because it can be difficult to define what a criminal mind is. Nevertheless, it is clear through the testimony of this particular case and its various motions for appeal that Williams does not appear to have what one may deem as a criminal mind for he has not omitted anything over the years since the crime in question was committed while his so called partner Draper admitted to killing the victim and named Williams his accomplice in the process. Evidently both the prosecution and the Supreme Court did not verify either actus reus or mens reus thus further demonstrating how this case needs to be readdressed by an outside party.
In conclusion the Supreme Court case Williams v Maryland illustrates how even though it was determined that the prosecution held back vital information, the petition to have the ruling appealed can be denied without an explanation. This is particularly important and revealing to me because the Supreme Court is supposed to be dedicated to discerning the guilty party and delivering justice, not rewarding those who break the rules and condemning a man who may or may not have taken part in murder to death even after numerous requests for an appeal. Apparently this does not seem to be fact as Williams is still in jail awaiting his execution while the prosecutor of the original case is sitting on the Supreme Court where they will decide even more life-altering cases. Thus it can be insisted that the Court does not work towards instilling justice but are more concerned with protecting and furthering their own agendas regardless of the consequences even if one of those consequences is a man put to death who may be innocent.
References
Krucias, L. M. (2000). Prosecutor's Duty to Disclose Exculpatory Evidence. Retrieved January 5, 2017, from http://ir.lawnet.fordham.edu/cgi/viewcontent.cgi?article=3689&context=flr
S. (2016). Williams v Pennsylvania. Retrieved January 5, 2017, from https://www.supremecourt.gov/opinions/15pdf/15-5040_6537.pdf
Strauss, P. (2016). Due Process. Retrieved January 05, 2017, from https://www.law.cornell.edu/wex/due_process