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Woodie LOUDRES v. The STATE of Texas

Court of Criminal Appeals of Texas, En Banc
614 S.W.2d 407 (1980)
ELI5:

Rule of Law:

A death sentence is invalid if prospective jurors are excluded for cause based solely on a state statute requiring them to affirm their deliberations will not be "affected" by the possibility of a death penalty, as this standard is broader than the constitutional standard established in Witherspoon v. Illinois, which only permits exclusion if a juror's views would prevent or substantially impair the performance of their duties.


Facts:

  • The appellant, his girlfriend Marlene Hughes, and his cousin Charlie Brooks were traveling in Fort Worth when Hughes' car broke down.
  • Brooks went to a nearby used car lot and asked to test drive a Pontiac Grand Prix.
  • David Gregory, a mechanic at the car lot, was instructed to accompany Brooks on the test drive.
  • Brooks drove to the disabled car, picked up the appellant, and then drove with both the appellant and Gregory to the New Lincoln Motel.
  • Appellant and Brooks took Gregory to Room 17 of the motel.
  • Motel employees heard gunshots, after which the appellant and Brooks left the motel.
  • Police later discovered Gregory's body in Room 17.

Procedural Posture:

  • The appellant was charged with capital murder in a Texas trial court.
  • During jury selection (voir dire), the State successfully challenged several prospective jurors for cause under Texas Penal Code Sec. 12.31(b).
  • The trial court sustained the State's challenges, excusing the jurors, and limited defense counsel's questions aimed at determining if the jurors met the exclusion standard under Witherspoon v. Illinois.
  • The empaneled jury convicted the appellant of capital murder and sentenced him to death.
  • The appellant directly appealed the conviction and sentence to the Texas Court of Criminal Appeals, the state's highest court for criminal cases.

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Issue:

Does excluding prospective jurors in a capital case for stating that the potential mandatory penalties of death or life imprisonment would "affect" their deliberations, pursuant to Texas Penal Code Sec. 12.31(b), and precluding defense counsel from asking questions to determine if they meet the Witherspoon standard for exclusion, violate the Sixth and Fourteenth Amendments?


Opinions:

Majority - Dally, J.

Yes. The exclusion of prospective jurors under Texas Penal Code Sec. 12.31(b) on grounds broader than those permitted under Witherspoon v. Illinois violates the U.S. Constitution. The recent Supreme Court decision in Adams v. Texas is controlling and holds that Sec. 12.31(b) cannot be used as a basis for juror exclusion independent of Witherspoon. In this case, the trial court excused multiple jurors solely because they stated the mandatory penalties would 'affect' their deliberations and foreclosed defense counsel's inquiry into whether they were nonetheless able to follow the law and their oath. Because the death penalty may not be imposed if even one prospective juror is excluded in violation of Witherspoon, the judgment must be reversed.


Concurring - Phillips, J.

Yes. The majority is correct to reverse based on Adams v. Texas. Additionally, there was separate reversible error in the admission of numerous extraneous offenses, such as the appellant's heroin addiction and history of shoplifting. The State improperly used this evidence to advance a 'two worlds' theory of prosecution, which served only to portray the appellant as a criminal generally, rather than proving the specific elements of the charged offense. This admission of character evidence was highly prejudicial and violated fundamental rules of criminal law.


Dissenting - Roberts, J.

While not directly answering the issue, the dissent opposes reversing the judgment of guilt. It takes exception to the majority's characterization of the court's prior jurisprudence on this issue. The dissent argues that the court had consistently held that Witherspoon applied to Texas's capital sentencing procedure, but that Section 12.31(b) was a valid, independent ground for excluding a juror, a position that was clear in the court's record.



Analysis:

This decision formally incorporates the U.S. Supreme Court's ruling in Adams v. Texas into Texas jurisprudence, ending the state's practice of using Penal Code Sec. 12.31(b) as an independent, and broader, basis for juror exclusion in capital cases. The ruling reinforces the supremacy of the Witherspoon standard, clarifying that a juror's general objections or conscientious scruples against the death penalty are not grounds for disqualification unless those views would substantially impair their ability to be impartial and follow the law. This holding significantly narrows the grounds upon which prosecutors in Texas can strike jurors for cause in capital cases, requiring any statutory qualification to be interpreted within the constraints of federal constitutional law.

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