Williams v. New York
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Later appellate decisions repeatedly reaffirmed Williams's precise rule for ordinary sentencing; most nearby adverse language treated another authority, reported another court's act, or rejected an argument that Williams had been overruled.
2,765 later cases cite Williams v. New York; 86 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Williams v. New York?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Limited
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The Supreme Court declined to extend Williams's relaxed sentencing procedures to a separate sex-offender proceeding that required a new factual finding and exposed the defendant to an indeterminate term of one day to life.
Specht v. Patterson · Supreme Court of the United States · filed
We adhere to Williams v. New York, supra; but we decline the invitation to extend it to this radically different situation. These commitment proceedings whether denominated civil or criminal are subject both to the Equal Protection Clause of the Fourteenth Amendment as we held in Baxstrom v. Herold, 383 U. S. 107, and to the Due Process Clause. We hold that the requirements of due process were not satisfied here.
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The Supreme Court held Williams inapplicable when a judge imposed death using confidential information that the defense had no opportunity to deny or explain.
Gardner v. Florida · Supreme Court of the United States · filed
Preliminarily, however, we note two comments by Mr. Justice Black that make it clear that the holding of Williams is not directly applicable to this case. [...] We conclude that petitioner was denied due process of law when the death sentence was imposed, at least in part, on the basis of information which he had no opportunity to deny or explain.
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The Eleventh Circuit confined Williams in capital sentencing by requiring cross-examination of adverse psychiatric experts; on rehearing, the panel limited that right to cases involving psychiatric reports.
Proffitt v. Wainwright · Eleventh Circuit · filed
The view, once prevalent, that the procedural requirements applicable to capital sentencing are no more rigorous than those governing noncapital sentencing decisions, see, e.g., McGautha v. California, 402 U.S. at 217, 91 S.Ct. at 1472; Williams v. New York, 337 U.S. at 251-52, 69 S.Ct. at 1085, is no longer valid. [...] The Supreme Court’s emphasis in Gardner and other capital sentencing cases on the reliability of the factfinding underlying the decision whether to impose the death penalty convinces us that the right to cross-examine adverse witnesses applies to capital sentencing hearings.
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The district court held that Williams's no-confrontation rule did not govern factfinding under the Federal Death Penalty Act and required confrontation during both the eligibility and selection phases.
United States v. Mills · C.D. Cal. · filed
Although Ring extends the Sixth Amendment’s right to a jury trial to the eligibility phase, it does not squarely address the right presently at issue: namely, the right to confrontation. However, the Supreme Court’s analysis in Ring strongly suggests that the Confrontation Clause also applies to the eligibility phase, in contravention of the Court’s earlier holding in Williams. [...] After analyzing the impact of those decisions, a task which is undertaken in the next section, the Court is left with the inexorable conclusion that confrontation rights must apply to the entirety of the penalty phase of capital trials, including the selection phase.
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