Estelle v. Smith Case Brief

Facts of the Case

After Ernest Benjamin Smith was indicted in Texas for murder, the State announced its intention to seek the death penalty. At an ensuing psychiatric examination, ordered by the trial court to determine Smith’s competency to stand trial and conducted in the jail where he was being held, the examining doctor determined that Smith was competent. Thereafter, Smith was tried by a jury and convicted. A separate sentencing proceeding was held before the same jury as required by Texas law. At such a proceeding, the jury was required to resolve three critical issues to determine whether the death sentence would be imposed. One of these issues involved whether there was a probability that Smith would commit criminal acts of violence that would constitute a continuing threat to society. At the sentencing hearing, the doctor who had conducted the pretrial psychiatric examination was allowed to testify for the State over defense counsels’ objection that his name did not appear on the list of witnesses the State planned to use at either the guilt or penalty stages of the proceedings. His testimony was based on the pretrial examination and stated in substance that Smith would be a danger to society. The jury then resolved the issue of future dangerousness, as well as the other two issues, against Smith, and thus under Texas law the death penalty was mandatory. The Texas Court of Criminal Appeals affirmed the conviction and death sentence. After unsuccessfully seeking a writ of habeas corpus in the state courts, Smith petitioned for such relief in federal district court. That court vacated the death sentence because it found constitutional error in admitting the doctor’s testimony at the penalty phase. A federal appellate court affirmed that decision.

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CONCLUSION

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Case Information

Citation: 451 US 454 (1981)
Argued: Oct 8, 1980
Decided: May 18, 1981
Case Brief: 1981