What is the question presented in Terence Tramaine Andrus, Petitioner v. Texas?

1. Whether a shackling claim under Deck v. Missouri, 544 U.S. 622 (2005), raised for the first time in a capital habeas proceeding and based on evidence only discovered through post-conviction interviews with jurors, can be properly deemed “procedurally barred” based on the conclusion that it could have been raised on direct appeal—even though the State’s capital procedures do not allow for the development or presentation of extra-record evidence on direct appeal? 2. How a Wiggins claim, based on mitigating evidence adduced only during the post-conviction investigation, should be assessed in light of the State’s case in aggravation at trial—where the trial counsel, accused of providing ineffective assistance, admitted under oath during the post-conviction proceeding that: he did not investigate any aspect of the State’s case in aggravation pre-trial or seek to rebut it during trial and in fact conceded to the jury in closing argument that the jury would likely find that the State had proven that his client would be a “future danger”?

What is Terence Tramaine Andrus, Petitioner v. Texas about?

from the Court of Criminal Appeals of Texas.

No. 18-9674October Term 2019Decided Jun 15, 2020

Docket 18-9674October Term 2019 (2019–2020)

Terence Tramaine Andrus, Petitioner v. Texas

The justices said Texas used too demanding a test in reviewing Andrus's claim that his lawyer performed badly at sentencing.

Case status

Current stage: Decided
Latest event: Decision released Jun 15, 2020

Case Accepted

Arguments

Decision ReleasedJun 15, 2020

What it's about: from the Court of Criminal Appeals of Texas.
Question presented
1. Whether a shackling claim under Deck v. Missouri, 544 U.S. 622 (2005), raised for the first time in a capital habeas proceeding and based on evidence only discovered through post-conviction interviews with jurors, can be properly deemed “procedurally barred” based on the conclusion that it could have been raised on direct appeal—even though the State’s capital procedures do not allow for the development or presentation of extra-record evidence on direct appeal? 2. How a Wiggins claim, based on mitigating evidence adduced only during the post-conviction investigation, should be assessed in light of the State’s case in aggravation at trial—where the trial counsel, accused of providing ineffective assistance, admitted under oath during the post-conviction proceeding that: he did not investigate any aspect of the State’s case in aggravation pre-trial or seek to rebut it during trial and in fact conceded to the jury in closing argument that the jury would likely find that the State had proven that his client would be a “future danger”?
Case path: Court of Criminal Appeals of Texas / Decision released Jun 15, 2020
Area: Criminal Procedure

Briefing

What it's about

Terence Andrus challenged how Texas handled claims tied to his death sentence, including a claim that his lawyer failed to uncover and present major mitigating evidence about his background. In a per curiam opinion, the Supreme Court said the Texas court appeared to use too strict a prejudice test when rejecting that ineffective-assistance claim.

Vote

The Court issued a per curiam opinion on June 15, 2020. The prompt does not provide a vote count or identify separate writings.

“The Court said the Texas court appeared to apply "a stricter standard of prejudice" than the one the Supreme Court's cases require.”
— Justice Per Curiam(majority)

Impact

The decision matters for death-penalty cases where important evidence comes out only after trial. For example, it affects defendants who say their lawyers failed to investigate childhood abuse, trauma, or other facts that might have changed a sentencing jury's view.

What's next

The Supreme Court has finished its work in this docket action. Any further proceedings would take place in the Texas courts under the Supreme Court's guidance.

What was the main dispute in Andrus v. Texas?

Andrus said Texas mishandled claims tied to his death sentence, including a claim that his lawyer failed to uncover and present major mitigating evidence.

Who could be affected by this decision in real life?

People in capital cases could be affected, especially when new evidence about abuse, trauma, or neglect appears after trial. State courts reviewing those claims are affected too.

What happens next in Andrus's case after the Supreme Court's decision?

The Supreme Court's role in this docket is over. Any next step would happen in the Texas courts, applying the Court's guidance.

Decision

Decision recordJun 15, 2020

What the Court decided

The justices said Texas used too demanding a test in reviewing Andrus's claim that his lawyer performed badly at sentencing.

Impact

Not official Court text.

Opinion documents

Strickland in a manner not inconsistent with this opinion Opinion

Documents

Opinions

Strickland in a manner not inconsistent with this opinion

Opinion

View full docket on supremecourt.gov

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View the full docket

Grounding

Grounding: Primary materials plus reporting.
Note: Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.
Checked: Jul 2, 2026
Method: Methodology

Primary materials7

Context reporting2