Robert O'neal v. Fred Mcaninch, Warden (513 U.S. 432)
U.S. Supreme Court · decided February 21, 1995 · Supreme Court Database (Spaeth)
- Citation
- 513 U.S. 432 · 115 S. Ct. 992
- Decided
- February 21, 1995
- Term
- October Term 1994
- Vote
- 6–3
- Majority author
- Justice Breyer
- Issue area
- Criminal Procedure
- Disposition
- Vacated and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice Breyer delivered the opinion of the Court. Reviewing courts normally disregard trial errors that are harmless. This case asks us to decide whether a federal ha-beas court should consider a trial error harmless when the court (1) reviews a state-court judgment from a criminal trial, (2) finds a constitutional error, and (3) is in grave doubt about whether or not that error is harmless. We recognize that this last mentioned circumstance, “grave doubt,” is unusual. Normally a record review will permit a judge to make up his or her mind about the matter. And indeed a judge has an obligation to do so. But we consider here the legal rule that governs the special circumstance in which record review leaves the conscientious judge in grave doubt about the likely effect of an error on the jury’s verdict. (By “grave doubt” we mean that, in the judge’s mind, the matter is so evenly balanced that he feels himself in virtual equipoise as to the harmlessness of the error.) We conclude that the uncertain judge should treat the error, not as if it were harmless, but as if it affected the verdict (i. e., as if it had a “substantial and injurious effect or influence in determining the jury’s verdict”). I Robert O’Neal filed a federal habeas corpus petition challenging his state-court convictions for murder and other crimes. The Federal District Court agreed with several of his claims of…
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