Buchanan v. Kentucky

Background

David Buchanan, a juvenile, was tried jointly with Kevin Stanford after the murder, rape, and robbery of a woman. Kentucky sought the death penalty against Stanford but not Buchanan. Buchanan asked the trial court not to exclude jurors who opposed the death penalty and sought separate juries; the court denied these motions. Buchanan’s lawyers presented psychological reports to support an extreme-emotional-disturbance defense, and the prosecutor had a social worker read an edited psychiatric evaluation prepared after a court-ordered examination. A jury convicted Buchanan and the state courts affirmed.

Reasoning

The Court addressed whether excluding jurors who cannot follow death-penalty law from a joint trial jury denied Buchanan an impartial, community-representative jury, and whether admitting a psychiatric report to rebut Buchanan’s mental-status evidence violated his rights. Relying on its prior McCree decision, the Court said the fair-cross-section rule applies to jury pools rather than the final jury and that excluding those who could not perform sentencing duties does not target a protected group. On the psychiatric issue, the Court distinguished Estelle v. Smith and explained that because Buchanan’s counsel had joined the evaluation and the defense introduced psychiatric evidence, the prosecution could use the examiner’s report in limited rebuttal without violating the Fifth or Sixth Amendment protections.

Real world impact

The ruling allows prosecutors to "death-qualify" juries in joint trials when a co-defendant faces capital punishment, even if the noncapital defendant is not eligible for death. Defense teams who introduce psychiatric evidence or request court-ordered evaluations should expect prosecution rebuttal with those evaluation reports. The decision emphasizes state interests in joint trials and trial efficiency over objections based on altered jury composition.

Dissents or concurrances

Justice Marshall (joined by Justices Brennan and partly Stevens) dissented, arguing that death-qualifying a jury for a noncapital defendant in a joint trial violated the right to an impartial jury and that admitting a therapeutic psychiatric report undermined treatment and violated Fifth and Sixth Amendment protections.