## Facts

- Carman L. Deck was convicted in Missouri of capital murder and related offenses for the robbery and killing of James and Zelma Long.
- The Missouri Supreme Court set aside Deck’s initial death sentence and ordered a new penalty-phase proceeding.
- At the resentencing before a jury, Deck was brought into court visibly restrained with leg irons, handcuffs, and a belly chain.
- Defense counsel objected to the visible restraints.
- The trial court overruled the objections and imposed no case-specific, on-the-record justification for shackling Deck.
- The jury again sentenced Deck to death.
- The Missouri Supreme Court affirmed the second death sentence, rejecting Deck’s federal constitutional challenge to the shackling.

## Issues

1. Whether the Due Process Clauses of the Fifth and Fourteenth Amendments prohibit visibly shackling a capital defendant during the penalty phase absent a case-specific, on-the-record justification.

## Decision

- The Supreme Court reversed in a 7–2 decision and remanded.
- The Court held that the Constitution forbids the routine use of visible shackles during the penalty phase of a capital trial, as during the guilt phase, unless justified by an essential state interest specific to the defendant.
- Because Deck was visibly shackled during the penalty proceeding without individualized findings supporting an essential state interest, the shackling violated due process.
- The Court treated visible shackling as inherently prejudicial on this record, and Missouri did not establish that the error was harmless.

## Legal Principles

- Due process generally prohibits physical restraints visible to the jury unless the trial court determines, in its discretion, that restraints are justified by an essential state interest specific to the particular defendant (e.g., courtroom security, escape prevention).
- The anti-shackling rule applies to capital sentencing proceedings because visible restraints can impair the defendant’s ability to present a meaningful case, detract from the dignity of the process, and create an unacceptable risk of influencing the jury’s life-or-death decision.
- A trial court may order restraints only after an individualized assessment tied to the defendant and the proceeding; routine or blanket shackling practices are unconstitutional when visible to the jury.

## Conclusion

The Court held that visibly shackling a defendant during the penalty phase of a capital trial violates due process unless the trial court makes case-specific findings that restraints are necessary to serve an essential state interest, and it reversed Deck’s death sentence because no such justification was provided.


Deck v. Missouri, 544 U.S. 622 (2005)