Brecht v. Abrahamson

Brecht (plaintiff) shot and killed his brother-in law and then left the state in his sister’s car. He was arrested and read his Miranda rights. At trial, Brecht claimed that the shooting was an accident. On cross examination, the prosecution repeatedly noted that Brecht had not claimed that the shooting was an accident at any time before trial. Brecht was convicted of first-degree murder and sentenced to life. On appeal, the court reversed Brecht’s conviction. The court held that the prosecution’s comments on Brecht’s post-Miranda silence regarding the accidental nature of the shooting violated Doyle v. Ohio, 426 U.S. 610 (1976), which prohibits the prosecution from using a defendant’s post-Miranda silence for impeachment purposes. The court held that the Doyle violation was prejudicial. The state supreme court reversed, holding that the error was harmless beyond a reasonable doubt under the standard established in Chapman v. California, 386 U.S. 18 (1967). Brecht petitioned in federal court for habeas corpus relief. The federal district court again set aside his conviction, finding that the error was prejudicial under the Chapman harmless error test. On appeal, the court again reversed and reinstated Brecht’s conviction. The court held that the wrong standard had been applied by the lower court; the correct standard for deciding whether to grant a defendant habeas corpus relief was whether the error had substantial and injurious effect on the verdict in the defendant’s case. The court held that the error in Brecht’s case did not meet this standard and that his conviction should not have been reversed. The Supreme Court granted certiorari.