Convicts Get Benefit of Doubt When State Courts Err
Feb. 21, 1995
WASHINGTON (AP) _ Convicted criminals deserve the benefit of the doubt when federal judges aren't sure whether errors in their state-court trials were harmless, the Supreme Court ruled Tuesday.
The 6-3 decision in an Ohio case made it easier for some prison inmates to win new trials by making it tougher for federal judges to excuse state trial errors as harmless.
Writing for the court, Justice Stephen G. Breyer said federal judges who have ``grave doubt'' about whether a state trial error was harmless should treat it as significant.
``The uncertain judge should treat the error not as if it were harmless but as if it affected the verdict,'' Breyer said as the high court revived an Ohio inmate's attempt to win a new murder trial.
Breyer noted that only a few convicted defendants may benefit from the ruling because ``grave doubt is unusual.''
The court's three dissenters _ Chief Justice William H. Rehnquist and Justices Clarence Thomas and Antonin Scalia _ took some comfort in that fact.
``Fortunately, the rule announced today will affect only a minuscule fraction of cases,'' Thomas wrote for the three.
They said no federal-court relief should be available if a convicted defendant cannot prove the errors made a difference in the verdict.
Defendants convicted in state courts routinely seek help from federal judges, contending that their prosecutions violated some federal constitutional right. Such appeals are called ``habeas corpus petitions.''
Robert O'Neal filed such an appeal after his murder conviction for the 1981 killing of Chicago businessman Henry Podborny was upheld by Ohio appellate courts.
Prosecutors said O'Neal, now serving a life prison sentence, was asked by Podborny's wife to kill him so she could claim her husband's assets. Podborny's corpse was found in a Cleveland field April 24, 1981.
O'Neal's federal appeal challenged a prosecutor's comments and the judge's instructions to the jury.
A federal judge agreed with O'Neal that constitutional errors had occurred, and ordered a new trial. But the 6th U.S. Circuit Court of Appeals ruled that the challenged comments and instructions, even if they were errors, had not been proved to be anything but harmless.
The appeals court relied on a 1993 Supreme Court ruling that relaxed, for habeas corpus cases, the requirement that federal appellate courts throw out convictions unless prosecutors prove the error was harmless ``beyond a reasonable doubt.''
The 1993 ruling said a less-stringent standard applies for federal habeas cases. Judges should leave state-court convictions intact unless an error exerted ``substantial influence on the course of the trial'' or led to ``actual prejudice to the accused,'' the 1993 ruling said.
The 6th Circuit court interpreted that ruling to have shifted the burden of proof from prosecutors to defendants in habeas corpus cases.
Tuesday's ruling set aside the appeals court's conclusion and sent O'Neal's case back to it.