Hedgpeth v. Pulido (2008)
- Docket
- 07-544
- Decided
- 2008-01-01
Summary
Question: Are jury instructions that instruct a jury on multiple theories of guilt, one of which is legally improper, necessarily "structural error" that exempts the instructions from a harmless-error review? Conclusion: No. In a 6-3 per curiam opinion, the Supreme Court held that the U.S. Court of Appeals for the Ninth Circuit inaccurately categorized the type of jury instructions in Mr. Pulido's case as "structural error." It reasoned that one instructional error arising in the context of multiple theories of guilt does not necessarily spoil all the jury's findings, which would entitle the convicted individual to automatic relief. Rather, the Court found that the jury instructions in Mr. Pulido's case should be evaluated by whether they caused a "substantial and injurious effect" upon the jury reaching its verdict. The Court vacated Mr. Pulido's conviction and remanded the case to the court of appeals for proceedings consistent with the decision. Justice John Paul Stevens dissented, joined by Justices David H. Souter and Ruth Bader Ginsburg. They found the U.S. Court of Appeals for the Ninth Circuit merely misused the term "structural error" in its opinion, while it actually utilized the analytical model advocated by the majority opinion. They reasoned that in the interests of efficiency, the Supreme Court should have affirmed the court of appeals rather than have it repeat largely the same analysis.