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Buck v. Thaler
565 U.S. 1022
SCOTUS
2011
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Background

  • Buck arrested for capital murder after killing his ex-girlfriend and her child; victim’s mother killed after逃 pursuit, with observed gloat by Buck.
  • Buck was sentenced to death based on a jury finding of future dangerousness to society.
  • Defense called Dr. Walter Quijano who testified that Buck would not be dangerous if imprisoned, including race-related statistical factors suggesting higher crime propensity for Black individuals.
  • Quijano’s report, stating race as an overrepresented factor among violent offenders, was admitted; defense elicited the race-related testimony on direct examination.
  • Prosecution briefly cross-examined on race and future dangerousness, but did not rely on race in closing; the district court learned of broader similar cases with race testimony.
  • Texas Attorney General publicly identified six cases with similar race-related testimony and later admitted error in five of them, but Buck’s case was initially treated differently; Buck moved for Rule 60 relief and Rule 59(e) relief after misstatements were revealed; the Fifth Circuit denied a COA, and the Supreme Court denied certiorari.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Rule 60 relief warranted given State’s misleading statements Buck Texas misstatements; Buck should get relief COA/relief remanded for consideration
Whether mischaracterizations tainted habeas record for Buck Buck Record not prejudiced; distinctions exist Record tainted; potential relief warranted
Whether certiorari denial should be granted given racial testimony in penalty phase Buck No fundamental error; similar to prior cases Certiorari denied

Key Cases Cited

  • Saldano v. Texas, 530 U.S. 1212 (2000) (acknowledged race-based sentencing error; remanded)
  • Miller-El v. Cockrell, 537 U.S. 322 (2003) (COA standard; whether jurisdictional thresholds met for habeas claims)
  • Alba v. Johnson, 232 F.3d 208 (5th Cir. 2000) (race-related testimony on direct/examination; separate from Buck’s case)
Read the full case

Case Details

Case Name: Buck v. Thaler
Court Name: Supreme Court of the United States
Date Published: Nov 7, 2011
Citation: 565 U.S. 1022
Docket Number: 11-6391
Court Abbreviation: SCOTUS