Chapman v. California (1966)
- Docket
- 95
- Decided
- 1966-01-01
- Category
- General
Summary
Question: (1) Are all federal constitutional errors harmful? (2) Did it constitute a harmless constitutional error when prosecutors improperly commented on Chapman and Teale’s failure to testify? Conclusion: No and no. In an 8-1 decision written by Justice Hugo Black, the Court affirmed that there may be some constitutional errors so unimportant and insignificant that they are harmless. Justice Black noted that all fifty states have harmless error statutes or rules, and that Congress established a longstanding rule for federal courts that judgments should not be reversed for errors that do not affect parties’ substantial rights. Justice Black determined that federal law must govern the application of a state harmless error rule; the Court cannot leave the formulation of rules protecting individuals from invasion by the states to those very same states. Justice Black then cited the holding from Fahy v. State of Connecticut , where the Court determined that an error is harmful if there is a reasonable possibility that the evidence complained of might have contributed to the conviction. Here, the prosecution repeatedly told the jury that by their silence Chapman and Teale had served as irrefutable witnesses against themselves; absent these comments, reasonable jurors might well have returned a not-guilty verdict. Thus, the state had not demonstrated beyond a reasonable doubt that the prosecutions’ comments did not contribute to Chapman and Teale’s conviction, and the error was harmful. Justice Potter Stewart concurred, noting that the Court previously reversed all convictions of guilt when defendants had given involuntary confessions at trial. Justice Stewart rejected the notion that such constitutional violations could ever be harmless. Justice John Harlan dissented, arguing that the state appellate court reasonably applied California’s harmless error rule to sustain Chapman and Teale’s conviction, and that California’s harmless error rule was consistent with the guarantee of fundamental fairness in the Fourteenth Amendment’s Due Process Clause. Justice Harlan rejected the majority’s assumption of a general supervisory power over the trial of federal constitutional issues, finding no source for that power in the Fourteenth Amendment.