California v. Roy (1996)
- Docket
- 95-2025
- Decided
- 1996-01-01
Summary
Question: Did the Court of Appeals, in applying a special harmless-error standard, apply a too-strict harmless-error standard for the purposes of federal habeas corpus review of a California trial judge's error in instructing a jury as to the elements of the crime of first-degree murder? Conclusion: Yes. In a per curiam opinion, the Court held that as a federal court reviewing a state-court determination in a habeas corpus proceeding, the Court of Appeals should have applied the harmless-error standard whether the error had substantial and injurious effect or influence in determining the jury's verdict. The Court reasoned that the error at issue, a misdescription of an element of the crime, was an error of omission and not an error of the structural sort in the trial mechanism that defies harmless-error analysis.