Adams v. Texas
448 U.S. 38 (1980)
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Rule of Law:
A prospective juror may not be excluded for cause from a capital case based on his or her views about capital punishment unless those views would prevent or substantially impair the performance of the juror's duties in accordance with the court's instructions and the juror's oath.
Facts:
- Adams was charged with the capital offense of murdering a peace officer in Texas.
- Texas capital trials are bifurcated, with a guilt-innocence phase followed by a separate sentencing phase.
- In the sentencing phase, the jury must answer three specific factual questions about the defendant's conduct and future dangerousness.
- If the jury unanimously answers 'Yes' to all three questions, the trial judge must impose a death sentence.
- During jury selection, prospective jurors were required by Texas Penal Code § 12.31(b) to take an oath stating that the mandatory penalty of death or life imprisonment would not affect their deliberations on any issue of fact.
- The State challenged for cause several prospective jurors who were unable or unwilling to take this oath.
- Some excluded jurors stated they would be 'affected' only in that the potential for a death sentence would cause them to take their role with greater seriousness or would involve them emotionally.
Procedural Posture:
- Adams was convicted of capital murder in a Texas trial court.
- Following a separate sentencing proceeding, the jury answered the three statutory questions in the affirmative, and the trial court imposed a mandatory death sentence.
- Adams (appellant) appealed to the Texas Court of Criminal Appeals, the state's highest court for criminal matters.
- On appeal, Adams argued that the trial court's exclusion of prospective jurors under Texas Penal Code § 12.31(b) violated the U.S. Constitution.
- The Texas Court of Criminal Appeals affirmed the conviction and sentence, holding that the juror selection process was consistent with Witherspoon v. Illinois.
- The U.S. Supreme Court granted Adams's petition for a writ of certiorari.
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Issue:
Does a Texas statute that disqualifies a prospective juror in a capital case who is unable to state under oath that the mandatory penalty of death or life imprisonment will not 'affect his deliberations on any issue of fact' violate the Sixth and Fourteenth Amendments?
Opinions:
Majority - Justice White
Yes. The exclusion of jurors under Texas Penal Code § 12.31(b) violates the Sixth and Fourteenth Amendments because it authorizes removals on a broader basis than that permitted by Witherspoon v. Illinois. The proper standard for exclusion is whether a juror's views on capital punishment would prevent or substantially impair the performance of their duties. The Texas statute's standard—whether a juror would be 'affected'—is too broad, as it excludes individuals who are willing and able to follow the law and their oath, but who honestly acknowledge that the gravity of the death penalty would invest their deliberations with greater seriousness or emotional involvement. Excluding such jurors biases the jury in favor of the death penalty and deprives the defendant of the impartial jury to which he is entitled.
Dissenting - Justice Rehnquist
No. The exclusion of jurors under the Texas statute does not violate the Constitution because the Texas sentencing scheme is fundamentally different from the one at issue in Witherspoon. Unlike the open-ended discretion in Witherspoon, the Texas procedure channels the jury's role into answering specific, objective factual questions. Given this limited role, the state has a legitimate interest in ensuring jurors can answer these questions based solely on the evidence, without being influenced by the ultimate penalty. The oath required by § 12.31(b) is a neutral and permissible means of ensuring that jurors will impartially perform their fact-finding duty, which is distinct from the broad moral decision-making addressed in Witherspoon.
Concurring - Justice Brennan
The author concurs with the Court's opinion but writes separately to reiterate his belief that the death penalty is, in all circumstances, cruel and unusual punishment prohibited by the Eighth Amendment.
Concurring - Justice Marshall
The author concurs in the judgment, agreeing that the exclusion of veniremen violated the doctrine of Witherspoon v. Illinois. However, he writes separately to reaffirm his position that the death penalty is per se unconstitutional as cruel and unusual punishment under the Eighth and Fourteenth Amendments.
Analysis:
This decision clarifies and extends the principles of Witherspoon v. Illinois to the 'guided discretion' capital sentencing schemes that became common after Furman v. Georgia. It establishes that the constitutional standard for excluding a juror for cause based on death penalty views is not merely being 'affected' but being unable to perform one's duties. This ruling significantly limits the state's ability to shape a capital jury, ensuring that jurors who take their responsibilities with special gravity due to the ultimate penalty are not automatically excluded, thereby protecting the defendant's right to an impartial jury drawn from a fair cross-section of the community.
