Brecht v. Abrahamson case brief summary
507 U.S. 619 (1993)
CASE FACTS
Petitioner was charged and sentenced to life imprisonment after he was convicted of first degree murder. The state court of appeals set petitioner's conviction aside on the ground that the state's references to petitioner's post-Miranda silence violated due process under Doyle. The state supreme court reinstated the conviction, and petitioner sought a writ of habeas corpus, reasserting his Doyle claim. The district court set aside the conviction, and the court of appeals reversed, holding that the Chapman harmless error standard, harmless beyond a reasonable doubt, did not apply in reviewing a Doyle error on federal habeas review. The court of appeals held that the standard for determining whether petitioner was entitled to habeas relief, as set forth in Kotteakos, was whether the Doyle violation had a substantial and injurious effect in determining the jury's verdict.
DISCUSSION
The Court affirmed the decision of the court of appeals, holding that the Doyle violation that occurred at petitioner's trial did not substantially influence the jury's verdict and, therefore, petitioner was not entitled to habeas relief. The Court concluded that the Kotteakos harmless error standard applied in determining whether habeas relief was required to be granted because of a constitutional error at trial.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
507 U.S. 619 (1993)
CASE SYNOPSIS
Certiorari was granted to review a
decision of the United States Court of Appeals for the Seventh
Circuit and to resolve a conflict of whether the Chapman harmless
error standard applied on collateral review of Doyle violations. The
court of appeals held that the standard for determining whether
petitioner was entitled to habeas relief was whether the Doyle
violation had a substantial and injurious effect in determining the
jury's verdict.CASE FACTS
Petitioner was charged and sentenced to life imprisonment after he was convicted of first degree murder. The state court of appeals set petitioner's conviction aside on the ground that the state's references to petitioner's post-Miranda silence violated due process under Doyle. The state supreme court reinstated the conviction, and petitioner sought a writ of habeas corpus, reasserting his Doyle claim. The district court set aside the conviction, and the court of appeals reversed, holding that the Chapman harmless error standard, harmless beyond a reasonable doubt, did not apply in reviewing a Doyle error on federal habeas review. The court of appeals held that the standard for determining whether petitioner was entitled to habeas relief, as set forth in Kotteakos, was whether the Doyle violation had a substantial and injurious effect in determining the jury's verdict.
DISCUSSION
- The United States Supreme Court agreed with the court of appeals in its determination of the appropriate harmless error standard.
- The Court held that the Doyle error that occurred at petitioner's trial did not substantially influence the jury's verdict and, therefore, petitioner was not entitled to habeas relief.
The Court affirmed the decision of the court of appeals, holding that the Doyle violation that occurred at petitioner's trial did not substantially influence the jury's verdict and, therefore, petitioner was not entitled to habeas relief. The Court concluded that the Kotteakos harmless error standard applied in determining whether habeas relief was required to be granted because of a constitutional error at trial.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
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