Buck v. Thaler
565 U.S. 1022
SCOTUS2011Background
- 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)
