Satterwhite v. Texas

John T. Satterwhite (defendant) was charged with murder. Prior to appointment of counsel, the judge granted the prosecution’s request for Satterwhite to undergo a psychological evaluation to determine his competency, mental state at time of the crime, and future dangerousness. After counsel was appointed, the prosecution made a second motion for evaluation on the same three grounds, which the judge granted. Neither the motion nor the order was served on Satterwhite’s attorney. Satterwhite was evaluated by Dr. James Grigson, a licensed psychiatrist with over 12-years’ experience. Grigson found Satterwhite to be very dangerous, have antisocial personality disorder, and concluded that Satterwhite would likely commit future crimes. Satterwhite was found guilty of murder by a jury. To enter a death sentence, the jury had to find that the defendant’s conduct was deliberate and that the defendant was likely to commit future acts of violence and posed a continuing threat. Over Satterwhite’s objection, Grigson testified during sentencing that Satterwhite was a sociopath who could not be medically treated and that Satterwhite posed a serious danger to society. Satterwhite was sentenced to death and filed an appeal. The court of appeals found that even if Grigson’s testimony violated Satterwhite’s Sixth Amendment rights, the error was harmless because the record contained sufficient evidence to support the death penalty. The United States Supreme Court granted review.