John, who suffered from severe developmental disabilities, who during out-of-court and in-court questioning was unable to distinguish between fantasy and reality, and who was declared incompetent as a witness by the court, was permitted to testify pursuant to the incompetency proviso of N. The State recalled John to the stand. He had difficulty answering simple questions.
The trial judge also charged the jury that it could draw adverse inferences from such failure. After the trial, but before petitioners' appeal was considered, the state constitutional provision was invalidated by Griffin v. Though admitting that petitioners had been denied a federal constitutional right, the California Supreme Court, applying the State Constitution's harmless error provision, upheld the convictions.
This Court has jurisdiction to formulate a harmless error rule that will protect a defendant's federal right under the Fifth and Fourteenth Amendments to be free from state penalties for not testifying in his criminal trial.
Before a constitutional error can be held to be harmless, the court must be able to declare its belief that it was harmless beyond a reasonable doubt.
The State in this case did not demonstrate beyond a reasonable doubt that the prosecutor's repetitive comments to the jury, and the trial court's instruction concerning the petitioners' failure to testify did not contribute to their convictions.
She was sentenced to life imprisonment, and he to death. At the time of the trial, Art. On appeal, the State Supreme Court, 63 Cal. In this Court, petitioners contend that both these questions are federal ones to be decided under federal law; that, under federal law, we should hold that denial of a federal constitutional right, no matter how unimportant, should automatically result in reversal of a conviction, without regard to whether the error is considered harmless, and that, if wrong in this, the various comments on petitioners' silence cannot, applying a federal standard, be considered harmless here.
I Before deciding the two questions here -- whether there can ever be harmless constitutional error and whether the error here was harmless -- we must first decide whether Page U.
The application of a state harmless error rule is, of course, a state question where it involves only errors of state procedure or state law.
But the error from which these petitioners suffered was a denial of rights guaranteed against invasion by the Fifth and Fourteenth Amendments, rights rooted in the Bill of Rights, offered and championed in the Congress by James Madison, who told the Congress that the "independent" federal courts would be the "guardians of those rights.
With faithfulness to the constitutional union of the States, we cannot leave to the States the formulation of the authoritative laws, rules, and remedies designed to protect people from infractions by the States of federally guaranteed rights.
We have no hesitation in saying that the right of these petitioners not to be punished for exercising their Fifth and Fourteenth Amendment right to be silent -- expressly created by the Federal Constitution itself -- is a federal right which, in the absence of appropriate congressional action, it is our responsibility to protect by fashioning the necessary rule.
II We are urged by petitioners to hold that all federal constitutional errors, regardless of the facts and circumstances, must always be deemed harmful.
Such a holding, Page U. We decline to adopt any such rule. All 50 States have harmless error statutes or rules, and the United States long ago, through its Congress, established for its courts the rule that judgments shall not be reversed for "errors or defects which do not affect the substantial rights of the parties.
All of these rules, state or federal, serve a very useful purpose insofar as they block setting aside convictions for small errors or defects that have little, if any, likelihood of having changed the result of the trial. We conclude that there may be some constitutional errors which, in the setting of a particular case, are so unimportant and insignificant that they may, consistent with the Federal Constitution, be deemed harmless, not requiring the automatic reversal of the conviction.
III In fashioning a harmless constitutional error rule, we must recognize that harmless error rules can work very unfair and mischievous results when, for example, highly important and persuasive evidence, or argument, though legally forbidden, finds its way into a trial in which the question of guilt or innocence is a close one.
What Page U. The federal rule emphasizes "substantial rights," as do most others. The California constitutional rule emphasizes "a miscarriage of justice," [ Footnote 6 ] but the California courts have neutralized this to some extent by emphasis, and perhaps overemphasis, upon the court's view of "overwhelming evidence.
Although our prior cases have indicated that there are some constitutional rights so basic to a fair trial that their infraction can never be treated as harmless error, [ Footnote 8 ] this statement in Fahy itself belies any belief that all trial errors which violate the Constitution automatically call for reversal.
At the same time, however, like the federal harmless error statute, it emphasizes an intention not to treat as harmless those constitutional errors that "affect substantial rights" of a party.
An error in admitting plainly relevant evidence which possibly influenced the jury adversely to a litigant cannot, under Fahy, be conceived Page U. Certainly error, constitutional error, in illegally admitting highly prejudicial evidence or comments, casts on someone other than the person prejudiced by it a burden to show that it was harmless.
It is for that reason that the original common law harmless error rule put the burden on the beneficiary of the error either to prove that there was no injury or to suffer a reversal of his erroneously obtained judgment. Connecticut about "whether there is a reasonable possibility that the evidence complained of might have contributed to the conviction" and requiring the beneficiary of a constitutional error to prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.
We therefore do no more than adhere to the meaning of our Fahy case when we hold, as we now do, that, before a federal constitutional error can be held harmless, the court must be able to declare a belief that it was harmless beyond a reasonable doubt. While appellate courts do not ordinarily have the original task of applying such a test, [ Footnote 10 ] it is a familiar standard to all courts, and we believe its adoption will provide a more workable standard, although achieving the same result as that aimed at in our Fahy case.
IV Applying the foregoing standard, we have no doubt that the error in these cases was not harmless to petitioners.The State in this case did not demonstrate beyond a reasonable doubt that the prosecutor's repetitive comments to the jury, and the trial court's instruction concerning the petitioners' failure to testify did not contribute to their convictions.
Define proof beyond a reasonable doubt. proof beyond a reasonable doubt synonyms, proof beyond a reasonable doubt pronunciation, proof beyond a reasonable doubt translation, English dictionary definition of proof beyond a reasonable doubt. A demonstration of the truth of a mathematical or logical statement, based on axioms .
beyond reasonable doubt’, upon which each and every criminal justice system is based. Therefore, every accused person irrespective of his or human identification in the legal proceedings of many nations.
17 require economic and legal reassessments (cost-benefit analysis) in. Proof beyond a reasonable doubt is proof that leaves you with an abiding conviction that the charge is true. The evidence need not eliminate all possible doubt because everything in life is open to some possible or imaginary doubt.
The panel did not address any state-law evidentiary claims and remanded to the family court to assess whether the State’s remaining evidence is sufficient to prove the adjudication beyond a reasonable doubt. The Supreme Court of Massachusetts stated that merely possessing a package received by mail or common carrier which contains drugs is not sufficient to support an inference beyond a reasonable doubt that the possessor knows the contents of the package.