California et al. v. Kenneth Duane Roy (519 U.S. 2)
U.S. Supreme Court · decided November 4, 1996 · Supreme Court Database (Spaeth)
- Citation
- 519 U.S. 2 · 117 S. Ct. 337
- Decided
- November 4, 1996
- Term
- October Term 1996
- Vote
- 9–0
- Issue area
- Criminal Procedure
- Disposition
- Vacated and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Per Curiam. A California court convicted respondent Kenneth Roy of the robbery and first-degree murder of Archie Mannix. The State’s theory, insofar as is relevant here, was that Roy, coming to the aid of a confederate who was trying to rob Mannix, helped the confederate kill Mannix. The trial judge gave the jury an instruction that permitted it to convict Roy of first-degree murder as long as it concluded that (among other things) Roy, “with knowledge of” the confederate’s “unlawful purpose” (robbery), had helped the confederate, i. e., had “aid[ed],” “promote[d],” “encourage[d],” or “instigate[d]” by “act or advice ... the commission of” the confederate’s crime. The California Supreme Court later held in People v. Beeman, 35 Cal. 3d 547, 561, 674 P. 2d 1318, 1326 (1984), that an identical instruction was erroneous because of what it did not say, namely, that state law also required the jury to find that Roy had the “knowledge [and] intent or purpose of committing, encouraging, or facilitating” the confederate’s crime. Id., at 561, 674 P. 2d, at 1326 (emphasis added). Despite this error, the California Court of Appeal affirmed Roy’s conviction because it found the error “harmless beyond a reasonable doubt.” See Chapman v. California, 386 U. S. 18, 24 (1967). The California Supreme Court denied postconviction relief. Subsequently Roy, pointing to the same instructional error,…
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