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Law School Case Brief

Deck v. Missouri - 544 U.S. 622, 125 S. Ct. 2007 (2005)

Rule:

Courts cannot routinely place defendants in shackles or other physical restraints visible to the jury during the penalty phase of a capital proceeding. The constitutional requirement, however, is not absolute. It permits 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 accommodates the important need to protect the courtroom and its occupants. But any such determination must 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.

Facts:

Petitioner Carman Deck was convicted of capital murder and sentenced to death, but the Missouri Supreme Court set aside the sentence. At his new sentencing proceeding, he was shackled with leg irons, handcuffs, and a belly chain. The trial court overruled counsel's objections to the shackles, and Deck was again sentenced to death. Affirming, the State Supreme Court rejected Deck's claim that his shackling violated, inter alia, the Federal Constitution. The United States Supreme Court granted Deck's petition for certiorari review.

Issue:

As a rule, may the courts place an accused in shackles or other physical restraints visible to the jury during the penalty phase of a capital proceeding?

Answer:

No

Conclusion:

The United States Supreme Court found that the appearance of Deck 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 Deck, and it thereby inevitably undermined the jury's ability to weigh accurately all relevant considerations when it determined whether Deck 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 their 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.

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