Buck v. Davis

Duane Buck was convicted and sentenced to death in Texas for the 1995 murders of his ex-girlfriend Debra Gardner and her friend Kenneth Butler. During the sentencing phase, defense expert Dr. Walter Quijano testified that African-American defendants are more likely to commit future crimes, and the prosecution emphasized this race-based testimony. Although Texas later conceded in a similar case that such testimony was unconstitutional, it refused to revisit Buck’s death sentence. Buck sought federal habeas relief, arguing his trial counsel provided ineffective assistance by introducing this racially biased evidence. The Supreme Court ruled 6-2 that Buck’s Sixth Amendment right to effective counsel was violated, as his attorney failed to challenge the discriminatory testimony, and that this error prejudiced the sentencing outcome. The decision allowed Buck a new sentencing hearing.

The U.S. Supreme Court reversed the Fifth Circuit, holding that Duane Buck’s death sentence was tainted by the ineffective assistance of counsel. The Court granted him habeas corpus relief and remanded the case for a new sentencing proceeding, where the racially biased evidence could not be used.

Whether defense counsel’s introduction of explicit race-based testimony linking black defendants to future dangerousness constituted ineffective assistance of counsel under the Sixth Amendment; whether the racial bias in the sentencing phase violated Buck’s right to due process; and whether the procedural default of the claim could be overcome under the Martinez/Trevino framework.

The decision condemned the use of racial stereotypes in capital sentencing and reinforced the constitutional prohibition against discrimination in the justice system. It prompted renewed scrutiny of other cases involving similar biased testimony, underscored the critical duty of defense attorneys to guard against racial prejudice, and contributed to broader efforts to eliminate racial bias in death penalty prosecutions.