Supreme Court of the United States
Deck v. Missouri
May 23, 2005544 U.S. 622
Summary
The Court held that due process bars routine use of visible shackles during the penalty phase of a capital case unless a case-specific state interest justifies them. Because the trial judge relied on Deck’s prior conviction without making an individualized security determination, and because Deck need not prove actual prejudice from unjustified visible shackling, the Court reversed and remanded. Justice Thomas, joined by Justice Scalia, dissented, arguing that history and state practice do not support the constitutional rule and that shackling at capital sentencing does not violate due process.
Holding
- Use of visible shackles during the penalty phase of a capital proceeding. Due process prohibits routine use of visible shackles during the penalty phase of a capital case. A judge may order restraints only after a case-specific determination that a state interest, such as courtroom security or escape prevention, justifies them.
- Whether Deck had to prove actual prejudice from unjustified shackling. When a court, without adequate justification, orders visible shackles that the jury sees, the defendant need not demonstrate actual prejudice to establish a due process violation; the State must prove beyond a reasonable doubt that the error did not contribute to the verdict.
Docket 04-5293
Cited authorities
- 15 St. Louis U. L.J. 351
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