Smith v. Texas (2007)

Last updated

Smith v. Texas
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Argued January 17, 2007
Decided April 25, 2007
Full case nameLaRoyce Lathair Smith v. Texas
Citations550 U.S. 297 ( more )
127 S. Ct. 1686; 167 L. Ed. 2d 632
Case history
Prior Smith v. Texas , 543 U.S. 37 (2004) ("Smith I"); Ex Parte Smith, 185 S.W.3d 455 (Tex. Crim. App. 2006); cert. granted, 549 U.S. 948(2006).
Holding
Texas Court of Criminal Appeals reversed[ further explanation needed ]
Court membership
Chief Justice
John Roberts
Associate Justices
John P. Stevens  · Antonin Scalia
Anthony Kennedy  · David Souter
Clarence Thomas  · Ruth Bader Ginsburg
Stephen Breyer  · Samuel Alito
Case opinions
MajorityKennedy, joined by Stevens, Souter, Ginsburg, Breyer
ConcurrenceSouter
DissentAlito, joined by Roberts, Scalia, Thomas
Laws applied
U.S. Const. amend. VIII

Smith v. Texas, 550 U.S. 297 (2007), was a United States Supreme Court case about a challenge to a Texas death penalty court procedure. Justice Anthony Kennedy wrote the opinion of the Court, holding 5-4 that the Texas procedure was improper. Justice Samuel Alito wrote a dissent.

Contents

Background

LaRoyce Lathair Smith was convicted of capital murder in the 1991 murder of a Dallas Taco Bell employee. [1] He was sentenced to death by a jury in Dallas County, Texas. In 2004, the Supreme Court overturned his death sentence because of an improper jury instruction and sent the case back to Texas state court. [2] After the case was remanded, the Texas Court of Criminal Appeals held that Smith’s pre-trial objections did not preserve the claim of constitutional error he asserted. "Under the Texas framework for determining whether an instructional error merits reversal, the state court explained, this procedural default required Smith to show egregious harm — a burden the court held he did not meet." [3] Smith appealed, and the Court granted certiorari . Smith's attorneys for the appeal included four retired federal appeals court judges. [4] The case was argued before the Supreme Court on January 16, 2007, with UT Austin Professor Jordan Steiker appearing for Smith and Texas Solicitor General Ted Cruz appearing for the state, with Gene Schaerr appearing for the State of California as a friend of Texas. [5]

Decision

Issue

The Court granted certiorari on two issues.

  1. Was the Texas Court of Criminal Appeals correct in holding that the improper jury instruction was harmless error and not sufficient to invalidate his death sentence?
  2. Was the Texas court correct to require a standard of "egregious harm" when evaluating whether an unconstitutional jury instruction should invalidate a death sentence?

Opinion of the Court

On April 24, 2007, the Supreme Court reversed and remanded. Justice Kennedy, writing for the 5-4 majority, held that the Texas Court "misunderstood the interplay of [previous death penalty decisions,] and it mistook which of Smith’s claims furnished the basis for this Court’s opinion in Smith I. These errors of federal law led the state court to conclude Smith had not preserved at trial the claim this Court vindicated in Smith I, even when the Court of Criminal Appeals previously had held Smith’s claim ... was preserved. The state court’s error of federal law cannot be the predicate for requiring Smith to show egregious harm."

Having resolved the second issue in Smith's favor, the Court did not address the first issue.

Concurrence

Justice Souter issued a brief concurrence, adding only that "in some later case, we may be required to consider whether harmless error review is ever appropriate in a case with error as described in Penry v. Lynaugh . We do not and need not address that question here." [6]

Dissent

Justice Alito dissented, stating that the issue was one of ordinary state procedure, and that Smith had indeed failed to raise any objection to the jury instruction. "Accordingly," he wrote, "I would dismiss for want of jurisdiction."

Subsequent developments

In 2008, one year after Smith v. Texas was decided, the subject, LaRoyce Smith, (former death row number #999007) had his sentence commuted to life imprisonment. [7]

Notes

  1. ↑ Smith, Jordan (November 19, 2004). "Supremes: What'd We Say?". Austin Chronicle . Retrieved January 10, 2008.
  2. ↑ See Smith I , 543 U.S. 37 (2004).
  3. ↑ Smith II, 550 U.S. at ___ (2007).
  4. ↑ Barnes, Robert (January 18, 2007). "High Court Hears 3 Death Penalty Cases". Washington Post . Retrieved January 10, 2008.
  5. ↑ "Smith v. Texas". Oyez.
  6. ↑ Internal citation omitted.
  7. ↑ http://www.tdcj.state.tx.us/death_row/dr_offenders_no_longer_on_dr.html

Related Research Articles

In law, certiorari is a court process to seek judicial review of a decision of a lower court or government agency. Certiorari comes from the name of an English prerogative writ, issued by a superior court to direct that the record of the lower court be sent to the superior court for review. The term is Latin for "to be made more certain", and comes from the opening line of such writs, which traditionally began with the Latin words "Certiorari volumus...".

<span class="mw-page-title-main">2005 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down sixteen per curiam opinions during its 2005 term, which lasted from October 3, 2005, until October 1, 2006.

<span class="mw-page-title-main">2004 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down six per curiam opinions during its 2004 term, which began October 4, 2004 and concluded October 3, 2005.

<span class="mw-page-title-main">2006 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down eight per curiam opinions during its 2006 term, which began October 2, 2006 and concluded September 30, 2007.

Tennard v. Dretke, 542 U.S. 274 (2004), was a United States Supreme Court case in which the court was asked whether evidence of the defendant's low IQ in a death penalty trial had been adequately presented to the jury for full consideration in the penalty phase of his trial. The Supreme Court held that not considering a defendant's low IQ would breach his Eighth Amendment rights and constitute a cruel and unusual punishment.

Kennedy v. Louisiana, 554 U.S. 407 (2008), is a landmark decision by the Supreme Court of the United States which held that the Eighth Amendment's Cruel and Unusual Punishments Clause prohibits the imposition of the death penalty for a crime in which the victim did not die and the victim's death was not intended.

<span class="mw-page-title-main">2009 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down nineteen per curiam opinions during its 2009 term, which began on October 5, 2009, and concluded October 3, 2010.

Snyder v. Louisiana, 552 U.S. 472 (2008), was a United States Supreme Court case about racial issues in jury selection in death penalty cases. Justice Samuel Alito, writing for the 7–2 majority, ruled that the prosecutor's use of peremptory strikes to remove African American jurors violated the Court's earlier holding in Batson v. Kentucky. Justice Clarence Thomas dissented.

<span class="mw-page-title-main">2010 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down ten per curiam opinions during its 2010 term, which began October 4, 2010 and concluded October 1, 2011.

Sackett v. Environmental Protection Agency, 566 U.S. 120 (2012), also known as Sackett I, is a United States Supreme Court case in which the Court held that orders issued by the Environmental Protection Agency under the Clean Water Act are subject to the Administrative Procedure Act. The Court ruled that because the Environmental Protection Agency's orders constitute "final agency action" under the Administrative Procedure Act, federal courts may hear appeals from its orders.

<i>Smith v. Spisak</i> 2010 United States Supreme Court case

Smith v. Spisak, 558 U.S. 139 (2010), was a United States Supreme Court decision on the applicability of the Antiterrorism and Effective Death Penalty Act of 1996. It further examined issues of previous court decisions on jury instructions and the effectiveness of counsel.

<span class="mw-page-title-main">2015 term per curiam opinions of the Supreme Court of the United States</span>

The Supreme Court of the United States handed down eighteen per curiam opinions during its 2015 term, which began October 5, 2015 and concluded October 2, 2016.

Kansas v. Carr, 577 U.S. 108 (2016), was a case in which the Supreme Court of the United States clarified several procedures for sentencing defendants in capital cases. Specifically, the Court held that judges are not required to affirmatively instruct juries about the burden of proof for establishing mitigating evidence, and that joint trials of capital defendants "are often preferable when the joined defendants’ criminal conduct arises out of a single chain of events". This case included the last majority opinion written by Justice Antonin Scalia before his death in February 2016.

McFadden v. United States, 576 U.S. 186 (2015), was a United States Supreme Court case in which the Court held that section 841 of the Controlled Substances Act requires the government to prove that to be in criminal violation, a defendant must be aware that an analogue defined by the Controlled Substance Analogue Enforcement Act with which he was dealing was a controlled substance.

Foster v. Chatman, 578 U.S. ___ (2016), was a United States Supreme Court case in which the Court held that the state law doctrine of res judicata does not preclude a Batson challenge against peremptory challenges if new evidence has emerged. The Court held the state courts' Batson analysis was subject to federal jurisdiction because "[w]hen application of a state law bar 'depends on a federal constitutional ruling, the state-law prong of the court’s holding is not independent of federal law, and our jurisdiction is not precluded,'" under Ake v. Oklahoma.

=

Moore v. Texas, 137 S. Ct. 1039 (2017), is a United States Supreme Court decision about the death penalty and intellectual disability. The court held that contemporary clinical standards determine what an intellectual disability is, and held that even milder forms of intellectual disability may bar a person from being sentenced to death due to the Eighth Amendment's prohibition against cruel and unusual punishment. The case clarified two earlier cases, Atkins v. Virginia (2002) and Hall v. Florida (2014).

United States v. Arthrex, Inc., 594 U.S. ___ (2021), was a United States Supreme Court case related to the Appointments Clause of the United States Constitution as it related to patent judges on the Patent Trial and Appeal Board (PTAB). In a complex decision, the Court ruled that these judges were considered "primary officers" under the Appointments Clause, normally subject to appointment through the US President and the US Senate, but to remedy the matter, the Court ruled that the constitutional issue is resolved by allowing the PTAB decisions to be subject to review by the appropriately-appointed Director of the Patent Office.

Chapman v. California, 386 U.S. 18 (1967), was a decision by the Supreme Court of the United States that a federal "harmless error" rule must apply, instead of equivalent state rules, for reviewing trials where federally-protected rights had been violated.

Smith v. United States, 599 U.S. 236 (2023), is a United States Supreme Court case pertaining to Article III and the Sixth Amendment. The Court held that a defendant may be retried following a jury trial conducted in the improper venue before a jury drawn from the incorrect district.

This page is based on this Wikipedia article
Text is available under the CC BY-SA 4.0 license; additional terms may apply.
Images, videos and audio are available under their respective licenses.