Opinion · Supreme Court of the United States

Sullivan v. Louisiana

Sullivan v. La., 508 U.S. 275 (1993)

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
1993-06-01
Topic
general

How later courts describe this case

  • holding that an instructional error that lessens the burden of proof is considered structural and not subject to harmless error analysis
  • holding that the deprivation of a defendant's Sixth Amendment right to trial by jury is a structural defect, not amenable to harmless error analysis
  • holding that the giving of an erroneous reasonable doubt instruction can never be harmless error
  • holding that a constitutionally deficient reasonable doubt instruction mandated reversal and that harmless error analysis was inapplicable in this situation
  • holding that harmless error analysis did not apply when a “beyond a reasonable doubt” instructional error consisted of a misdescription of burden of proof
  • concluding that it is structural error for a court to give an incorrect definition of 4 “reasonable doubt”
  • holding that the right to trial by jury is a “basic protection whose precise effects are unmeasurable, but without which a criminal trial cannot reliably serve its function”
  • holding that correct inquiry for harmless error review is "whether the guilty verdict actually rendered in this trial was surely unattributable to the error" (second emphasis added)

Citator

Sullivan v. Louisiana is good law as far as the corpus records: followed by 1 later decision, and nothing recorded condemns it.

Authority status
positive
Cited by
3477 opinions
Followed
1 times
Distinguished
1 times

Headnotes

  1. Criminal Law & Procedure — Right to Jury Trial The Sixth Amendment right to a jury trial in serious criminal cases includes, as its most important element, the right to have the jury, rather than the judge, reach the requisite finding of guilt; although a judge may direct a verdict for the defendant on legally insufficient evidence, he may not direct a verdict for the State no matter how overwhelming the evidence. 508 U.S. 275, 277 (1993)
  2. Criminal Law & Procedure — Burden of Proof The Due Process Clause requires the prosecution to bear the burden of proving all elements of the offense charged and to persuade the factfinder beyond a reasonable doubt of the facts necessary to establish each of those elements; this requirement applies in state as well as federal proceedings. 508 U.S. 275, 277-278 (1993)
  3. Criminal Law & Procedure — Right to Jury Trial The Fifth Amendment requirement of proof beyond a reasonable doubt and the Sixth Amendment requirement of a jury verdict are interrelated; the jury verdict required by the Sixth Amendment is a verdict of guilt beyond a reasonable doubt, and it does not satisfy the Sixth Amendment to have a jury determine that the defendant is probably guilty while leaving to the judge the determination whether he is guilty beyond a reasonable doubt. 508 U.S. 275, 278 (1993)
  4. Criminal Law & Procedure — Harmless Error Chapman v. California instructs a reviewing court to consider the actual effect of a constitutional error on the guilty verdict in the case at hand—whether the guilty verdict actually rendered was surely unattributable to the error—rather than what effect the error might generally be expected to have on a reasonable jury; to hypothesize a guilty verdict that was never in fact rendered would violate the jury-trial guarantee. 508 U.S. 275, 279 (1993)
  5. Criminal Law & Procedure — Harmless Error Harmless error review is unavailable where the trial court gave a constitutionally deficient reasonable doubt instruction: because there has been no jury verdict of guilt beyond a reasonable doubt within the meaning of the Sixth Amendment, the premise of harmless error review is absent, and an appellate court could only speculate as to what a reasonable jury would have done—in effect permitting the wrong entity to judge the defendant guilty. 508 U.S. 275, 279-281 (1993)
  6. Criminal Law & Procedure — Harmless Error A jury instruction that misdescribes the burden of proof by defining reasonable doubt in a constitutionally deficient manner is distinguishable from an unconstitutional presumption regarding an element of the offense, because a jury instructed to presume an element from predicate facts must still find those predicate facts beyond a reasonable doubt, permitting a reviewing court to conclude the presumption played no significant role in the finding of guilt; a misdescription of the burden of proof vitiates all the jury's findings. 508 U.S. 275, 280-281 (1993)
  7. Criminal Law & Procedure — Structural Error Denial of the right to a jury verdict of guilt beyond a reasonable doubt is a structural defect in the constitution of the trial mechanism that defies analysis by harmless error standards, because its consequences are necessarily unquantifiable and indeterminate and the jury guarantee is a basic protection without which a criminal trial cannot reliably serve its function. 508 U.S. 275, 281-282 (1993)