United States Supreme Court
507 U.S. 619 (1993)
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.
Rule of Law
Holding and Reasoning (Rehnquist, C.J.)
Concurrence (Stevens, J.)
Dissent (White, J.)
Dissent (O’Connor, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 221,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,100 briefs, keyed to 189 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.