Summary
The United States Supreme Court held that a violation of the Fifth and Fourteenth Amendments may be subject to harmless-error review. It adopted the rule that a federal constitutional error is harmless only when the beneficiary of the error proves beyond a reasonable doubt that it did not contribute to the verdict. The Court reversed the petitioners' convictions because extensive prosecutorial comments and jury instructions concerning their failure to testify were not harmless beyond a reasonable doubt.
Topics
Practice areas
Questions Presented
- Whether federal or state law governs the determination of whether a federal constitutional error is harmless in a state criminal prosecution.
- Whether a violation of Griffin v. California can ever be held harmless and, if so, whether the error in this case was harmless.
Holdings
- The question whether a state conviction should stand when the State has denied federally guaranteed rights is a federal question, and federal law governs the application of a harmless-error rule to such a denial.
- No; there may be some constitutional errors so unimportant and insignificant in the setting of a particular case that they may, consistent with the Federal Constitution, be deemed harmless and not require automatic reversal.
- Before a federal constitutional error can be held harmless, the court must be able to declare a belief that it was harmless beyond a reasonable doubt.
- No; the prosecutor's comments and the trial court's instruction on petitioners' silence were not harmless beyond a reasonable doubt.
Key quotations
“The question is whether there is a reasonable possibility that the evidence complained of might have contributed to the conviction.” (23-24)
“We, therefore, do no more than adhere to the meaning of our Fahy case when we hold, as we now do, that before a federal constitutional error can be held harmless, the court must be able to declare a belief that it was harmless beyond a reasonable doubt.” (24)
“Such a machine-gun repetition of a denial of constitutional rights, designed and calculated to make petitioners' version of the evidence worthless, can no more be considered harmless than the introduction against a defendant of a coerced confession.” (26)
Factual background
Petitioners Chapman and Teale were convicted in a California state court of robbing, kidnapping, and murdering a bartender, with Chapman sentenced to life imprisonment and Teale to death. At trial, both declined to testify, and the prosecutor repeatedly commented on their silence, with the trial court instructing the jury that adverse inferences could be drawn from that silence. After the trial but before the state appeal, Griffin v. California held that such comment violated the Fifth and Fourteenth Amendments. The California Supreme Court nevertheless affirmed the convictions, applying the state harmless-error provision.
Procedural history
Petitioners were convicted in California state court on charges of robbery, kidnapping, and murder. The California Supreme Court affirmed, admitting that Griffin v. California had been violated but applying the state constitution's harmless-error provision. The United States Supreme Court granted certiorari limited to whether a Griffin error may be harmless and, if so, whether it was harmless in this case.
Remand instructions
Reversed and remanded for a new trial free from the unconstitutional comment on petitioners' failure to testify.