Tuesday, November 5, 2013

Deck v. Missouri case brief

Deck v. Missouri case brief summary
544 U.S. 622 (2005)

Petitioner was convicted of capital murder and sentenced to death. At a sentencing proceeding, he was shackled with leg irons, handcuffs, and a belly chain. The trial court overruled counsel's objections to the shackles, and the petitioner was sentenced to death. The Missouri Supreme Court rejected petitioner's claim that his shackling violated the Federal and Missouri Constitutions. The petitioner filed a motion for writ of certiorari.


  • The Court found that the appearance of the offender during the penalty phase in shackles, almost inevitably implied to a jury, as a matter of common sense, that court authorities considered the offender a danger to the community. 
  • It also almost inevitably affected adversely the jury's perception of the character of defendant, and it thereby inevitably undermined the jury's ability to weigh accurately all relevant considerations when it determined whether defendant deserved death. 
  • Therefore, the Court held that courts could not routinely place defendants in shackles or other physical restraints visible to the jury during the penalty phase of a capital proceeding. However, the constitutional requirement was not absolute. 
  • It permitted a judge, in the exercise of his or her discretion, to take account of special circumstances, including security concerns, that may call for shackling. 
  • In so doing, it accommodated the important need to protect the courtroom and its occupants. 
  • But any such determination had to be case specific; that is to say, it should reflect particular concerns, say special security needs or escape risks, related to the defendant on trial.
The judgment was reversed, and the case was remanded for further proceedings.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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