Adams v. Texas

1980-06-25

Headline: Death-penalty jury rules limited: Court blocks Texas from excluding jurors simply because the prospect of execution might “affect” their deliberations and reverses a defendant’s death sentence.

Holding: The Court held that Texas improperly excluded jurors under §12.31(b) in ways inconsistent with Witherspoon, reversed the petitioner’s death sentence, and protected jurors who might be emotionally affected but can follow their oath and instructions.

Real World Impact:

Reverses an individual death sentence because juror exclusions were improper.
Limits striking jurors who say the death penalty might emotionally affect deliberations.
Permits exclusion only for jurors unable to follow instructions or take the oath.

Topics: death penalty, jury selection, capital sentencing, Texas criminal law

Summary

Background

A man charged with killing a peace officer in Texas was tried under the State’s two-phase capital system. After a guilty verdict, a separate sentencing jury answered three statutory questions; if all were “Yes,” the trial judge had to impose death. During jury selection Texas asked prospective jurors to swear that the mandatory penalty of death or life imprisonment would not “affect” their deliberations, and the trial court excluded several jurors who would not give that oath.

Reasoning

The Court examined whether Witherspoon v. Illinois — which bars excluding jurors solely for qualms about capital punishment — applies to Texas’s bifurcated sentencing. The Court said it does. Texas may exclude only those jurors whose views would prevent them from following the law or taking their oath. But the State went too far here by excluding people who said the possibility of death would simply make their deliberations more serious or might in some way affect them emotionally; such feelings do not prove inability to follow instructions.

Real world impact

The Court found the exclusions under Tex. Penal Code § 12.31(b) were broader than Witherspoon permits and reversed the death sentence. Moving forward, Texas courts must keep jurors who will honestly apply the law even if they acknowledge emotional concern about the death penalty; only jurors who cannot obey the oath or the court’s instructions may be excluded.

Dissents or concurrances

Justices Brennan and Marshall agreed with reversal but reiterated their view that the death penalty is always unconstitutional. Justice Rehnquist dissented, arguing Texas’s guided sentencing left little jury discretion and would have upheld the oath requirement.