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Sullivan v. Louisiana

    Brief Fact Summary. An individual was charged with first-degree murder during the course of the robbery of a bar. At trial, the jury instructions included a definition of reasonable doubt that was previously found unconstitutional.

    Synopsis of Rule of Law. “[T]he reviewing court [should] consider [ ] not what effect the constitutional error might generally be expected to have upon a reasonable jury, but rather what effect it had upon the guilty verdict in the case at hand.”

    Facts. The Petitioner, Sullivan (the “Petitioner”), was charged with first-degree murder during the course of the robbery of a bar. The Petitioner’s alleged accomplice, Michael Hillhouse (“Hillhouse”) testified during trial pursuant to a grant of immunity. The bar was crowded, but only one witness testified during trial. The witness could not identify either the Petitioner or Hillhouse during a physical line up, but testified that he saw the Petitioner hold a gun to the victim’s head. In his closing argument, the defense counsel argued there was reasonable doubt as to the identity of the murderer and his intent.
    The trial judge gave a definition of reasonable doubt that was previously found unconstitutional in [Cage v. Louisiana]. The Petitioner was found guilty of first-degree murder. The Supreme Court of Louisiana held that the jury instruction pertaining to reasonable doubt was harmless.

    Issue. “[W]hether a constitutionally deficient reasonable doubt instruction may be harmless error[?]”

    Held. The majority observed the “prosecution bears the burden of proving all elements of the offense charged and must persuade the factfinder ‘beyond a reasonable doubt’ of the facts necessary to establish each of those elements.”
    “It is self-evident, we think, that the Fifth Amendment requirement of proof beyond a reasonable doubt and the Sixth Amendment requirement of a jury verdict are interrelated. It would not satisfy the Sixth Amendment to have a jury determine that the defendant is probably guilty, and then leave it up to the judge to determine (as Winship requires) whether he is guilty beyond a reasonable doubt. In other words, the jury verdict required by the Sixth Amendment is a jury verdict of guilty beyond a reasonable doubt.”
    The majority observed “[i]n [Chapman v. California], we rejected the view that all federal constitutional errors in the course of a criminal trial require reversal. We held that the Fifth Amendment violation of prosecutorial comment upon the defendant’s failure to testify would not require reversal of the conviction if the State could show ‘beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.’ ” The Chapman standard recognizes that ‘certain constitutional errors, no less than other errors, may have been harmless in terms of their effect on the factfinding process at trial.’ Although most constitutional errors have been held amenable to harmless error analysis, some will always invalidate the conviction.”
    “Consistent with the jury trial guarantee, the question [Chapman] instructs the reviewing court to consider is not what effect the constitutional error might generally be expected to have upon a reasonable jury, but rather what effect it had upon the guilty verdict in the case at hand. Harmless error review looks, we have said, to the basis on which ‘the jury actually rested its verdict.’ The inquiry, in other words, is not whether, in a trial that occurred without the error, a guilty verdict would surely have been rendered, but whether the guilty verdict actually rendered in this trial was surely unattributable to the error. That must be so, because to hypothesize a guilty verdict that was never in fact rendered – no matter how inescapable the findings to support that verdict might be – would violate the jury-trial guarantee.”
    “[T]he essential connection to a ‘beyond a reasonable doubt’ factual finding cannot be made where the instructional error consists of a misdescription of the burden of proof, which vitiates all the jury’s findings. A reviewing court can only engage in pure speculation – its view of what a reasonable jury would have done. And when it does that, ‘the wrong entity judge[s] the defendant guilty.’ ”
    Likewise, “[i[n [Arizona v. Fulminante], we distinguished between, on the one hand, ‘structural defects in the constitution of the trial mechanism, which defy analysis by ‘harmless error’ standards,’ and, on the other hand, trial errors which occur ‘during the presentation of the case to the jury, and which may therefore be quantitatively assessed in the context of other evidence presented.’ Denial of the right to a jury verdict of guilt beyond a reasonable doubt is certainly an error of the former sort, the jury guarantee being a ‘basic protectio[n]’ whose precise effects are unmeasurable, but without which a criminal trial cannot reliably serve its function. The right to trial by jury reflects, we have said, ‘a profound judgment about the way in which law should be enforced and justice administered.’ The deprivation of that right, with consequences that are necessarily unquantifiable and indeterminate, unquestionably qualifies as ‘structural error.’ ”

    Discussion. This case deals with the effects that errors during trial have when an appellate court is reviewing the case.


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