Deck v. Missouri

Background

Carman Deck, a convicted murderer, killed and robbed an elderly couple and was convicted and sentenced to death. After the State of Missouri set aside the first sentence, a new penalty hearing began. From the start of the new proceeding Deck wore leg irons, handcuffs, and a belly chain that the jury could see. His lawyer repeatedly objected, but the trial judge refused to remove the restraints and said Deck had been convicted and would remain shackled.

Reasoning

The Court examined whether the Constitution allows visible restraints during the penalty phase of a capital case. Relying on longstanding common-law practice and prior decisions, the majority held that the Fifth and Fourteenth Amendments forbid routine visible shackling that juries can see unless the judge makes a case-specific determination that an essential state interest, such as courtroom security or preventing escape, justifies the restraint. The Court found the record here lacked such findings, noted the jury was aware of the shackles, and explained that where shackling is ordered without adequate justification the defendant need not show actual prejudice; the State must prove beyond a reasonable doubt the error did not affect the outcome.

Real world impact

Judges must explain and record specific safety or escape-related reasons before ordering visible restraints at capital sentencing. Defendants in penalty proceedings now have a constitutional protection against routine visible shackling, though the ruling allows restraints when a tailored security need is shown. The case was reversed and sent back to Missouri for further proceedings consistent with this rule.

Dissents or concurrances

Justice Thomas (joined by Justice Scalia) dissented, arguing history and state practice do not support this rule and warning it could impede courtroom security and discretionary practices of trial courts.