Deck v. Missouri

Deck v. Missouri, 544 U.S. 622 (2005), was a United States Supreme Court case that dealt with the constitutionality of shackling a prisoner during the sentencing phase of a trial. In a 7–2 opinion delivered by Justice Breyer , the court held that it is against due process , a right prescribed by the Fifth and Fourteenth Amendments , to shackle a defendant in the sentencing portion of a trial unless the shackling relates to a specific defendant and certain state interests.

Contents

• 1 Background

  • 1.1 Petitioner's argument

  • 1.2 Amicus curiae briefs

• 2 Opinion of the Court

  • 2.1 Majority opinion

  • 2.2 Dissent

• 3 Execution

• 4 See also

• 5 References

• 6 External links

Background

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On August 27, 1996, Carman Deck (August 9, 1965 – May 3, 2022) was officially charged and arrested for six felonies. Among those felonies were a count of first-degree robbery, a count of first-degree burglary, two counts of armed criminal action, and two counts of first-degree murder. During the guilt phase of Deck's original trial, he was dressed as a normal citizen, but had leg-braces under his clothes. Deck's trial began on February 17, 1998, and within three days, he was convicted on all counts. After handing down a verdict, it took the jury only one additional day to sentence Deck to death. After the trial, Deck appealed to the Supreme Court of Missouri , where his conviction and sentence were upheld. However, Deck was later granted a new penalty phase after he appealed to the Supreme Court of Missouri on the grounds that he received ineffective assistance of counsel at sentencing.

The retry of Deck's penalty phase began on April 29, 2003, where he was brought into court wearing shackles. The defense objected to Deck being visibly restrained, stating that Deck's behavior did not justify shackles. The defense stated the only justification for shackling Deck would have been if he caused a disturbance in the courtroom. However, he did not. The defense also suggested other measures that the court could have taken to ensure safety instead of shackling Deck. These measures included adding extra security guards to the courtroom, and having the people who wanted to sit in the gallery walk through metal detectors. However, the defense's objections were overruled. Deck's attorneys once again objected during voir dire . Deck's defense thought that asking jurors if the shackles biased them was not enough to ensure that Deck would receive reliable sentencing. The court overruled the objection again, stating “The objection that you’re making will be overruled. He has been convicted and will remain in leg irons and belly chain.” The jury once again sentenced Deck to death.

Deck appealed to the Supreme Court of Missouri, arguing that the shackles infringed upon his right to due process , equal protection , right to confront evidence against him, and freedom from cruel and unusual punishment (prescribed from Fifth , Sixth , Eighth , and Fourteenth Amendments to the United States Constitution ). The Missouri Supreme Court held that the trial court had standing to impose security measures if it was necessary. The Supreme Court of Missouri stated that Deck had committed murder and that he would run if he had the chance. Additionally, the court ruled that there was “no record of the extent of the jury’s awareness of the restraints throughout the penalty phase.” The Missouri Supreme Court concluded by stating that it was not claimed that the shackles prevented Deck from participating in the trial and that no evidence has been put forth to prove that it did.

Petitioner's argument

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Deck and his attorneys submitted a Writ of Certiorari to the United States Supreme Court to try to get his death sentence thrown out. The Writ of Certiorari laid out Deck's arguments as to why the shackling was unconstitutional. Deck and his counsel claimed that some of Deck's basic constitutional rights were violated when he was shackled in open court.

Deck specifically claimed that his rights to due process , prescribed by the Fifth and Fourteenth Amendments , were violated. Deck's counsel made it clear that there was no reason such as a court disturbance to permit such shackling. In Deck's argument to the Supreme Court , it was also argued that Deck's Sixth Amendment rights had been violated on the grounds of the Confrontation Clause . Deck's shackling told the jury that Deck was dangerous and was shackled to protect the courtroom, resulting in what his attorneys referred to as prejudice towards Deck, i.e. the jury may have been influenced by these arbitrary details in deciding Deck's sentence, not just the presented facts. As a result, his right to confront witnesses as stated in the 6th Amendment (as well as the requirement of an impartial jury) were violated by the shackles. Deck's counsel argued that the shackles violated the defendant's rights that "give meaning to the defendant’s right to be present at his trial". It was argued that the shackles limited Deck from freely conversing with his counsel, and that they prevented him from taking the stand to defend himself. The defense wrote that this would increase the chances of Deck being sentenced to death by the jury which made the shackling unconstitutional.

Additionally Deck argued that his Eighth Amendment rights had been violated because of the idea of reliable sentencing. This also ties into the idea of a biased jury. According to justices Souter and Stevens’ concurring opinion in the case of _Simmons v. South Carolina _, the “Eight Amendment requires provision of accurate sentencing information as an indispensable prerequisite to a reasoned determination of whether a defendant shall live or die” (case from 1994). Deck's attorneys argued that since the jury considered arbitrary evidence, Deck's right to reliable sentencing had been violated.

Deck and his attorneys also argued about the burden of proof. Deck's counsel believed that the bias created by the shackles put the burden of proof on Deck and not the state. The defense argued that the state could not prove that the shackles did no harm. Ultimately, the defense felt that the shackling of Deck was not harmless beyond a reasonable doubt , meaning shackling made a difference in the decision that the jury made. The defense argued that this alone was a violation against the constitution and due process.

Amicus curiae briefs

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An _amicus curiae _ brief was filed by Thomas H. Speedy Rice on behalf of the Bar Human Rights Committee of England and Wales and the National Association of Criminal Defense Lawyers on behalf of Deck (petitioner).

In their brief, the Bar of Human Rights Committee and

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