Buck v. Davis Case Brief

Facts of the Case

“Petitioner Duane Buck was convicted of capital murder in a Texas court. Under state law, the jury was permitted to impose a death sentence only if it found unanimously and beyond a reasonable doubt that Buck was likely to commit acts of violence in the future. Buck’s attorney called a psychologist, Dr. Walter Quijano, to offer his opinion on that issue. Dr. Quijano had been appointed to evaluate Buck by the presiding judge and had prepared a report setting out his conclusions. To determine the likelihood that Buck would act violently in the future, Dr. Quijano had considered a number of statistical factors, including Buck’s race. Although Dr. Quijano ultimately concluded that Buck was unlikely to be a future danger, his report also stated that Buck was statistically more likely to act violently because he is black. The report read, in relevant part: “Black: Increased probability.” Despite knowing the contents of the report, Buck’s counsel called Dr. Quijano to the stand, where he testified that race is a factor “know n to predict future dangerousness.”. Dr. Quijano’sreport was admitted into evidence at the close of his testimony. The prosecution questioned Dr. Quijano about his conclusions on race and violence during cross-examination, and it relied on his testimony in summation. During deliberations, the jury requested and received the expert reports admitted into evidence, including Dr. Quijano’s. The jury returned a sentence of death.”

Question

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CONCLUSION

“The U.S. Court of Appeals for the Fifth Circuit applied the wrong standard of review when it denied Buck’s Certificate of Appealability (COA) for failing to demonstrate extraordinary circumstances. Chief Justice John G. Roberts, Jr., delivered the opinion for the 6-2 majority, which held that the proper standard of review in COA analysis was whether Buck’s claim was reasonably debatable. An appellate court should not consider the actual merits of an appeal unless it first determined that the claim was reasonably debatable. In this case, by essentially deciding the appeal on its actual merits and then denying Buck’s COA based on that adjudication, the Fifth Circuit inverted the COA analysis and imposed an undue burden on Buck. The Court also held that Buck successfully demonstrated ineffective assistance of counsel. It reasoned that Buck received inadequate assistance of counsel because his attorney introduced evidence that Buck was liable to be a future danger because of his race, and that it was reasonably probable that without this testimony he may not have been sentenced to death. Finally, the Court held that the district court’s denial of Buck’s motion for habeas relief was an abuse of discretion and noted that there was a reasonable probability that Buck was sentenced to death in part based on his race. To punish someone based on an immutable characteristic, the Court noted, “is a disturbing departure from a basic premise of our criminal justice system: Our law punishes people for what they do, not who they are.”Justice Clarence Thomas filed a dissenting opinion in which he argued that the majority opinion misapplied settled law in order to reach the outcome it desired. Under the majority’s construction of the COA analysis, no COA could ever be denied. The proper construction of the COA analysis requires that, in order to deny a COA because the prisoner’s claim is not reasonably debatable, a court must first determine that it is meritless. Justice Thomas also argued that Buck failed to demonstrate ineffective assistance of counsel because he did not demonstrate that his counsel materially prejudiced his defense. Additionally, Justice Thomas wrote that the district court’s denial of Buck’s motion for habeas relief was not an abuse of discretion, and he criticized the level of deference shown by the majority towards the findings of the district court.”

Case Information

Citation: 580 US (2017)
Granted: Jun 6, 2016
Argued: Oct 5, 2016
Decided: Feb 22, 2017
Case Brief: 2017