Smith v. Texas (2007)

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Smith v. Texas
Supreme Court of the United States
Argued January 17, 2007
Decided April 25, 2007
Full case name: LaRoyce Lathair Smith v. Texas
Citations: 550 U.S.
Holding
Texas Court of Criminal Appeals reversed
Court membership
Chief Justice: John Glover Roberts, Jr.
Associate Justices: John Paul Stevens, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer, Samuel Alito
Case opinions
Majority by: Kennedy
Joined by: Stevens, Souter, Ginsburg, Breyer
Concurrence by: Souter
Dissent by: Alito
Joined by: Roberts, Scalia, Thomas
Laws applied
Eighth Amendment to the United States Constitution

Smith v. Texas, 550 U.S. ___ (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

[edit] Facts and procedural history

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]

[edit] Decision

[edit] 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?

[edit] Opinion of the Court

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.

[edit] 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."[5]

[edit] 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."

[edit] External links

[edit] Notes

  1. ^ Smith, Jordan. "Supremes: What'd We Say?", Austin Chronicle, 2004-11-19. Retrieved on 2008-01-10. 
  2. ^ See Smith I, 543 U.S. 37 (2004).
  3. ^ Smith II, 550 U.S. at ___ (2007).
  4. ^ Barnes, Robert. "High Court Hears 3 Death Penalty Cases", Washington Post, 2007-01-18. Retrieved on 2008-01-10. 
  5. ^ Internal citation omitted.
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