Taylor v. Kentucky - 436 U.S. 478 (1978)
U.S. Supreme Court
Taylor v. Kentucky, 436 U.S. 478 (1978)
Taylor v. Kentucky
Argued March 27, 1978
Decided May 30, 1978
436 U.S. 478
At petitioner's Kentucky state robbery trial, which resulted in his conviction, the trial court instructed the jury as to the prosecutor's burden of proof beyond a reasonable doubt but refused, inter alia, petitioner's requested instruction on the presumption of innocence. The robbery victim was the prosecution's only witness, and petitioner was the sole defense witness. The prosecutor, in his opening statement, related the circumstances of petitioner's arrest and indictment. In his closing statement, the prosecutor made observations suggesting that petitioner's status as a defendant tended to establish his guilt. The Kentucky Court of Appeals affirmed the conviction, rejecting petitioner's argument that he was entitled to the requested instruction as a matter of due process under the Fourteenth Amendment.
Held: On the facts, the trial court's refusal to give petitioner's requested instruction on the presumption of innocence resulted in a violation of his right to a fair trial as guaranteed by the Due Process Clause of the Fourteenth Amendment. Howard v. Fleming, 191 U. S. 126, distinguished. Pp. 436 U. S. 483-490.
(a) While the legal scholar may understand that the presumption of innocence and the prosecution's burden of proof are logically similar, the ordinary citizen may draw significant additional guidance from an instruction on the presumption of innocence. Pp. 436 U. S. 483-485.
(b) An instruction on the presumption is one way of impressing upon the jury the importance of an accused's right to have his guilt or innocence determined solely on the basis of evidence introduced at trial and not on grounds of official suspicion, indictment, continued custody, or other circumstances not adduced as proof at trial. Pp. 436 U. S. 485-486.
(c) The prosecutor's remarks during his opening and closing statements, together with the skeletal instructions of the trial court, gave rise to a genuine risk that the jury would convict petitioner on the basis of extraneous considerations, rather than on the proof adduced at the trial, a risk heightened by the fact that the trial was essentially a swearing contest between victim and accused. Pp. 436 U. S. 486-488.
(d) That the trial court instructed as to the burden of proof beyond a reasonable doubt did not obviate the necessity for a presumption of innocence instruction in view of both the special purpose of such an instruction and the particular need for it in this case. P. 436 U. S. 488.
(e) Nor did the fact that defense counsel argued the presumption of innocence in both his opening and closing statements dispense with the need for a presumption of innocence instruction, since arguments of counsel cannot substitute for instructions by the court. Pp. 436 U. S. 488-489.
551 S.W.2d 813, reversed and remanded.
POWELL, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, STEWART, WHITE, MARSHALL, and BLACKMUN, JJ., joined. BRENNAN, J., filed a concurring statement, post, p. 436 U. S. 490. STEVENS, J., filed a dissenting opinion, in which REHNQUIST, J., joined, post, p. 436 U. S. 491.