APPELLANT JAMAL'S MOTION TO RECUSE JUSTICE RONALD D. CASTILLE FROM ANY
FURTHER PROCEEDINGS IN THIS ACTION.
COMES NOW Appellant Mumia Abu-Jamal and
hereby moves this Court for an Order recusing Justice Ronald D. Castille from
any further proceedings in this action and, in support thereof, alleges and says
as follows:
INTRODUCTION
- Appellant Jamal previously presented to this Court a motion for remand to
take testimony under oath from Justice Ronald D. Castille with regard to his
responsibility for the infamous McMahon videotape, produced by the
Philadelphia District Attorneys' Office during Castille's administration. The
videotape, which instructs Assistant District Attorneys on how to utilize
peremptory challenges to ethnically cleanse juries of African-Americans, was
officially condemned by this Court in Commonwealth v Basemore, 560 Pa 258, 744
A2d 717, 731, n. 12 (2000), for recommending practices "which flaunt
constitutional principles in a highly flagrant manner." The videotape's first
frame bears the name Ronald D. Castille and his title as District Attorney,
the Official Seal of the City of Philadelphia, and the logo of DATV
Productions, the video production department of the Philadelphia District
Attorneys' Office.
- Justice Castille recused himself from participating in this Court's
consideration and subsequent denial of Appellant Jamal's remand motion to take
his testimony, although the Justice did not recuse himself from participating
in this Court's consideration and denial in 1998 of Appellant's motion for
remand to supplement his Batson claim with the McMahon videotape and to
conduct discovery with regard to it, nor did the Justice recuse himself from
this Court's consideration and denial in that same year of Appellant Jamal's
appeal from denial of post-conviction relief. Commonwealth v Abu-Jamal, 720
A2d 79, 86 (Pa. 1998).
- Justice Castille's recent self-recusal from consideration of Appellant's
remand motion to take his testimony with regard to the Justice's
responsibility for the McMahon videotape itself provides a basis to grant this
recusal motion as it is just as inappropriate for the Justice to have any
further participation in the proceedings in this action as it would have been
for him to participate in ruling on the motion to take his testimony with
regard to the McMahon videotape.
I. JUSTICE CASTILLE SHOULD BE RECUSED FROM ANY FURTHER PARTICIPATION IN
THESE PROCEEDINGS BECAUSE THE POST-CONVICTION/STATE HABEAS PETITION UNDERLYING
THIS APPEAL CONTAINS A BATSON CLAIM.
Appellant Jamal's Petition for Post-Conviction Relief and/or Writ of
Habeas Corpus which underlies the instant appeal herein contains a Batson
claim as sub-issue 7 of the Ninth Claim for Relief. The unique circumstances
and grave miscarriage of justice considerations which underlie Appellant's
arguments with regard to this Court's (and the Court of Common Pleas')
inherent power to entertain that Petition on its merits is inextricably
interwoven with the merits of the underlying claims in the Petition.
Justice Castille was District Attorney during the pendency of Appellant's
direct appeal, which included a Batson claim, which the District Attorneys
Office opposed. Justice Castille previously participated in ruling on and
denying Appellant Jamal's appeal from denial of post-conviction relief, which
included a Batson claim, without disclosing to the Court or the parties his
official responsibility for the McMahon videotape in his capacity as District
Attorney, as evidenced by its bearing his name and title as District Attorney
alongside the Official Seal of the City of Philadelphia and the logo of DATV
Productions. Additionally, Justice Castille participated in this Court's
denial of Appellant Jamal's remand motion to take evidence concerning the
McMahon videotape, submitted while that appeal was under submission, also
without disclosing his responsibility for the videotape.
II. THE
PHILADELPHIA DISTRICT ATTORNEYS' STRIKE RATE FOR BLACK JURORS EXPERIENCED ITS
MOST DRAMATIC INCREASE DURING THE CASTILLE ADMINISTRATION AFTER THE BATSON
DECISION CAME DOWN AND THE MCMAHON VIDEOTAPE WAS PRODUCED.
The Baldus Study, which covers the period 1981 through 1997, includes a
specific discussion of the McMahon videotape (3 U. Pa. J. Const. L. 3, 41-43)
and provides a wealth of statistical data which suggests that the racially
discriminatory tactics taught to prosecutors in that videotape were utilized
throughout that period to keep African-Americans from serving on juries. Of
direct relevance to this recusal motion is the graph set forth in Figure 4 of
the Baldus Study (3 U. Pa. J. Const. L. at 75) which shows that, although the
United States Supreme Court decision in Batson v Kentucky,476 US 79 (1986)
came down in the first year that Justice Ronald D. Castille was Philadelphia
District Attorney, the strike rate of Black jurors by Philadelphia prosecutors
did not decrease, but dramatically increased, beginning in the period
1986-1987, to reach a significantly higher level in the period 1989-1990, than
in either the preceding Rendell administration or the succeeding Abraham
administration. The McMahon videotape, which teaches prosecutors numerous
means of removing Blacks from juries while disguising the discriminatory
purpose of so doing, was produced in the 1986-1987 period.
III. OF THE
THREE BATSON DECISIONS BY THIS COURT INVOLVING THE MCMAHON VIDEOTAPE WHICH ARE
KNOWN TO APPELLANT'S COUNSEL , THE ONLY ONE IN WHICH RELIEF WAS GRANTED WAS
THAT IN WHICH JUSTICE CASTILLE RECUSED HIMSELF.
Appellant Jamal's counsel have found three decisions of this Court ruling
on Batson claims involving the McMahon videotape: Commonwealth v Basemore, 560
Pa 258, 744 A2d 717 (2000); Commonwealth v Lark, 560 Pa 487, 746 A2d 585
(2000); and Commonwealth v Rollins, 558 Pa 532, 738 A2d 435 (1999).
A careful review of the particular circumstances of each of these cases
provides strong additional support for granting this motion to recuse Justice
Castille.
Basemore, the only decision in which Justice Castille did not participate,
is the only decision out of these three Batson cases in which this Court
granted appellate relief to a petitioner on a Batson claim and ordered the
matter remanded for an evidentiary hearing. In Lark and Rollins, in which
Justice Castille did participate, the petitioner's Batson claim was denied by
this Court on the basis that a prima facie case was not established despite
the evidence of the McMahon videotape.
In Basemore this Court directly ruled that the practices taught in the
McMahon videotape with regard to jury selection by prosecutors in criminal
cases were in "highly flagrant" violation of the United States Constitution:
"[W]e condemn in the strongest terms the practices described in the transcript
presented [of the McMahon videotape], which flaunt constitutional principles
in a highly flagrant manner." 744 A2d at 731, n.
This Court itself enumerated those practices as follows: "In the document
[i.e., the transcript of the McMahon videotape]: the purpose of voir dire,
namely, to select a fair and impartial jury, is denigrated as ridiculous,' in
favor of the selection of jurors who will be biased in favor of conviction;
various racial and gender stereotypes are described and offered as reasons to
discriminate in the selection of jurors; techniques for accomplishing such
discrimination are described in detail, including the maintenance of a running
tally of the race of the venire panel and the invention of pretextual reasons
for exercising peremptory challenges; and a willingness to deceive trial
courts to manipulate jury panels to these ends is also expressed." 744 A2d at
729.
IV. THIS
COURT RULED IN BASEMORE THAT THERE IS AN UNQUESTIONABLE INFERENCE OF
"INVIDIOUS DISCRIMINATION" ON THE PART OF ANY PROPONENT OF THE PRACTICES
DESCRIBED IN THE MCMAHON VIDEOTAPE.
After specifically quoting numerous shocking excerpts from the transcript
of the McMahon videotape (744 A2d at 730-731), this Court specifically held
that "[t]here can be no question that the practices described in the
transcript support an inference of invidious discrimination on the part of any
proponent." 744 A2d at 731-732 [emphasis added]. It must be emphasized that
this Court did not limits its finding in this regard to Mr. McMahon himself,
but ruled instead that there is an unquestionable inference of invidious
discrimination on the part of any proponent of these practices.
V. THE TERM
"ANY PROPONENT" OF THESE PRACTICES MUST NECESSARILY INCLUDE THE DISTRICT
ATTORNEY WHOSE NAME AND TITLE APPEAR IN THE FIRST FRAMES OF THE VIDEOTAPE
ALONG WITH THE OFFICIAL SEAL OF THE CITY OF PHILADELPHIA EJUSTICE RONALD D.
CASTILLE.
The conclusion is inescapable that the term "any proponent" of these
practices must necessarily include the District Attorney whose name and title
(as well as the Official Seal of the City of Philadelphia) appear in the first
frames of the McMahon videotape, viz. Ronald D. Castille. There is no evidence
that Justice Castille, when he was District Attorney, ever disavowed the
McMahon videotape which bears his own name and title, either within the
District Attorneys Office to those Assistant District Attorneys for whose
conduct he was responsible as their ultimate supervisor, or publicly. To the
contrary, the very existence of the videotape was not publicly revealed until
Castille's successor, Lynne Abraham, used it to discredit Mr. McMahon when he
ran against her as a candidate for the position of District Attorney.
In Basemore, this Court found that "tactics of the sort reflected in the
transcript [of the McMahon videotape] impugn the legitimacy of the judicial
process." 744 A2d at 733 [emphasis added]. Given Justice Castille's
responsibility for the McMahon videotape's production by the District
Attorneys' Office during his administration, and his failure to the present
day to disavow the practices advocated therein Epractices which this Court
held in Basemore to raise an inference of "invidious discrimination" by any
proponent of such practices Eany further participation by him in the
proceedings in this action would violate Article V, Section 18 of the
Pennsylvania Constitution which specifically enumerates as conduct for which a
judge may be disciplined "conduct which prejudices the proper administration
of justice" and "conduct which brings the judicial office into disrepute."
VI. JUSTICE CASTILLE PARTICIPATED IN THIS COURT'S DECISIONS IN LARK AND
ROLLINS WITHOUT DISCLOSING TO THE COURT OR THE PARTIES THE FACT THAT HIS NAME
AND TITLE AS DISTRICT ATTORNEY APPEAR IN THE FIRST FRAMES OF THE MCMAHON
VIDEOTAPE ALONGSIDE THE OFFICIAL SEAL OF THE CITY OF PHILADELPHIA AND THE LOGO
OF "DATV PRODUCTIONS."
In Rollins this Court, with Justice Castille participating in the
decision, rejected a Batson claim underlying an "ineffective assistance of
counsel" claim on grounds of failure to make a prima facie showing of improper
use of peremptory challenges, despite the evidence of the McMahon videotape.
The Rollins Court specifically ruled as follows:
Appellant also claims that the existence of a training tape
created [emphasis added] by then-Assistant District Attorney Jack McMahon
(who did not prosecute Appellant) in 1987, which instructed prosecutors to
manipulate the jury selection process in order to minimize the seating of
African-American jurors, supports his Batson claim. Appellant is incorrect
as the existence of the tape does not demonstrate that there was
discrimination in his case. 738 A2d at 443, n. 10.
However, Justice Castille participated in that decision without disclosing
to the Court or the parties that, rather than having been "created" by Mr.
McMahon, the videotape was, in fact, created by DATV Productions, and in its
first two frames bears the name and title of Ronald D. Castille as District
Attorney, alongside the Official Seal of the City of Philadelphia and the logo
of the District Attorneys Office video production department. Such evidence
would necessarily have proved up the appellant's prima facie case.
In Lark, this Court relied, in part, upon its earlier decision in Rollins,
to find similarly that no prima facie case had been established under Batson
despite the evidence of the McMahon videotape:
"We reject Appellant's suggestion that Attorney McMahon's
statements during a training session in 1986 or 1987 governed the conduct of
a different prosecutor in 1985 merely because both attorneys worked in the
same office. We have also previously determined that the tape is not
sufficient to establish a policy of discrimination in jury selection by the
prosecutors in the District Attorney's Office of Philadelphia County ...
[citing Rollins] Thus, the McMahon tape in and of itself does not
demonstrate that there was discrimination in his case ... [again citing
Rollins] and cannot form an independent basis for a Batson claim." 746 A2d
at 589.
Again, Justice Castille participated in this decision without disclosing
to the Court or the parties that his name and title as District Attorney
appeared in the first frames of the McMahon videotape alongside the Official
Seal of the City of Philadelphia and the logo of the District Attorneys Office
video production department, DATV Productions. Such evidence would have
established the prima facie case which the Court held had not been proved. Nor
did Justice Castille disclose that the assumption which underlay the Court's
earlier decision in Rollins, i.e., that the videotape was "created" by
McMahon, was not only false, but would be refuted by the evidence of his own
responsibility for the videotape as evidenced by its bearing his name and
title as District Attorney.
Finally, in the case of Appellant Mumia Abu-Jamal, as noted above, Justice
Castille participated in this Court's prior decisions in 1998 denying his
remand motion to conduct discovery with regard to the very same McMahon
videotape which bears the Justice's name and prior title as District Attorney
and denying Appellant's appeal of denial of post-conviction relief, an appeal
which included a Batson claim, without disclosing to this Court or the parties
his responsibility for the McMahon videotape.
Under the above-elucidated circumstances, for Justice Castille to
participate in further proceedings in this matter would be in violation of
Article V, Section 18 of the Pennsylvania Constitution which specifically
enumerates as conduct for which a judge may be disciplined "conduct which
prejudices the proper administration of justice" and "conduct which brings the
judicial office into disrepute." Moreover, for Justice Castille to participate
any further in the proceedings in this case, given his past conduct in
participating in this Court's decisions in the above-enumerated cases, and his
prior rulings in the case of Appellant Jamal, would represent an egregious
violation of the Code of Judicial Conduct, Canon 1 ("A judge should uphold the
integrity and independence of the judiciary."), Canon 2 ("A judge should avoid
impropriety and the appearance of impropriety in all his activities.") and
Canon 3(1) (A judge "should perform the duties of his office impartially and
diligently.").
Moreover, for Justice Castille to have any further participation in the
proceedings in this appeal would violate Appellant Jamal's right under the
Fifth and Fourteenth Amendments to the United States Constitution to a hearing
before an impartial tribunal free of improper judicial bias. See, e.g.,Berger
v United States (1921) 255 US 22; United States v Grinnell Corp. (1966) 384 US
563; and Likety v United States (1994) 510 US 540.
CONCLUSION
For all of the foregoing reasons, Appellant's motion for remand to take
testimony under oath of Justice Ronald D. Castille should be granted.
Dated: July 3, 2002
Respectfully submitted,
MUMIA ABU-JAMAL Appellant
NICK BROWN
ELIOT LEE GROSSMAN
MARLENE KAMISH
Attorneys for
Appellant Mumia Abu-Jamal
MIKE FARRELL
Local Counsel for Appellant