Sullivan v. Louisiana
Annotate this Case
508 U.S. 275 (1993)
OCTOBER TERM, 1992
SULLIVAN v. LOUISIANA
CERTIORARI TO THE SUPREME COURT OF LOUISIANA No. 92-5129. Argued March 29, 1993-Decided June 1, 1993
The jury instructions in petitioner Sullivan's state-court trial for first-degree murder included a definition of reasonable doubt that was essentially identical to the one held unconstitutional in Cage v. Louisiana, 498 U. S. 39 (per curiam). The jury entered a verdict of guilty, and Sullivan was sentenced to death. In upholding the conviction on direct appeal, the Supreme Court of Louisiana held that the erroneous instruction was harmless beyond a reasonable doubt.
Held: A constitutionally deficient reasonable-doubt instruction cannot be harmless error. Pp. 277-282.
(a) Sullivan's Sixth Amendment right to jury trial was denied by the giving of a constitutionally deficient beyond-a-reasonable-doubt instruction. The Fifth Amendment requirement of proof beyond a reasonable doubt, see, e. g., In re Winship, 397 U. S. 358, 364, and the Sixth Amendment requirement that the jury, rather than the judge, reach the requisite finding of guilty, are interrelated: The required jury verdict is a verdict of guilt beyond a reasonable doubt. The Court's opinion in Cage, which held that an instruction of the sort given here does not produce such a verdict, is controlling. Pp. 277-278.
(b) The giving of a constitutionally deficient reasonable-doubt instruction is among those constitutional errors that require reversal of a conviction, rather than those that are amenable to harmless-error analysis. See Chapman v. California, 386 U. S. 18,24. Consistent with the jurytrial guarantee, Chapman instructs a reviewing court to consider the actual effect of the error on the guilty verdict in the case at hand. Since in petitioner's case there has been no jury verdict within the meaning of the Sixth Amendment, the premise for harmless-error analysis is absent. Unlike an erroneous presumption regarding an element of the offense, see Sandstrom v. Montana, 442 U. S. 510, a deficient reasonable-doubt instruction vitiates all the jury's factual findings. A reviewing court in such a case can only engage in pure speculationits view of what a reasonable jury would have done. When it does that, the wrong entity judges the defendant guilty. Moreover, denial of the right to a jury verdict of guilt beyond a reasonable doubt, the consequences of which are necessarily unquantifiable and indeterminate, is certainly a "structural defec[t] in the constitution of the trial mechanism, which def[ies] analysis by 'harmless-error' standards" under Arizona v.
Fulminante, 499 U. S. 279, 309 (opinion of REHNQUIST, C. J., for the Court). Pp. 278-282.
596 So. 2d 177, reversed and remanded.
SCALIA, J., delivered the opinion for a unanimous Court. REHNQUIST,
John Wilson Reed, by appointment of the Court, 506 U. S. 996, argued the cause for petitioner. With him on the briefs were William J. Keppel, Michael J. Wahoske, Christopher
Jack Peebles argued the cause for respondent. With him on the brief was Harry F. Connick. *
JUSTICE SCALIA delivered the opinion of the Court.
The question presented is whether a constitutionally deficient reasonable-doubt instruction may be harmless error.
Petitioner was charged with first-degree murder in the course of committing an armed robbery at a New Orleans bar. His alleged accomplice in the crime, a convicted felon named Michael Hillhouse, testifying at the trial pursuant to a grant of immunity, identified petitioner as the murderer. Although several other people were in the bar at the time of the robbery, only one testified at trial. This witness, who had been unable to identify either Hillhouse or petitioner at a physical lineup, testified that they committed the robbery, and that she saw petitioner hold a gun to the victim's head. There was other circumstantial evidence supporting the conclusion that petitioner was the triggerman. 596 So. 2d 177, 180-181 (La. 1992). In closing argument, defense counsel argued that there was reasonable doubt as to both the identity of the murderer and his intent.
* Barry S. Simon filed a brief for the National Association of Criminal Defense Lawyers as amicus curiae urging reversal.
Disclaimer: Official Supreme Court case law is only found in the print version of the United States Reports. Justia case law is provided for general informational purposes only, and may not reflect current legal developments, verdicts or settlements. We make no warranties or guarantees about the accuracy, completeness, or adequacy of the information contained on this site or information linked to from this site. Please check official sources.