California v. Roy
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519 U.S. 2 (1996)
OCTOBER TERM, 1996
CALIFORNIA ET AL. v. ROY
ON PETITION FOR WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT
No. 95-2025. Decided November 4,1996
A California court convicted respondent Roy of robbery and first-degree murder. The State contended that Roy, coming to the aid of a confederate who was committing the robbery, helped with the murder. The jury was instructed that it could convict if, inter alia, Roy, with knowledge of the confederate's unlawful purpose, had helped the confederate. The State Supreme Court later held an identical instruction erroneous because it did not require the jury to find that a defendant had the knowledge and intent or purpose of committing, encouraging, or facilitating the confederate's crime. Despite this error, the State Court of Appeal affirmed Roy's conviction, finding that the error was "harmless beyond a reasonable doubt." See Chapman v. California, 386 U. S. 18, 24. The Federal District Court considering Roy's habeas claim also found the error harmless, reasoning that no rational juror could have found that Roy knew the confederate's purpose and helped him but also did not intend to help him. In reversing, the en banc Ninth Circuit applied a special harmless-error standard, which it believed combined aspects of the decisions in Carella v. California, 491 U. S. 263 (per curiam), and O'Neal v. McAninch, 513 U. S. 432, and held that the omission of the instruction's intent part is harmless only if a review of the assistance and knowledge facts found by the jury establish that the jury necessarily found the omitted intent element.
Held: As a federal court reviewing a state-court determination in a habeas corpus proceeding, the Ninth Circuit should have applied the harmless-error standard first enunciated in Kotteakos v. United States, 328 U. S. 750, namely, whether the error had substantial and injurious effect or influence in determining the jury's verdict. The Ninth Circuit drew its standard from a discussion in Carella's concurring opinion about the proper way to determine whether an error in respect to the use of a legal presumption was harmless. Subsequent to Carella, however, this Court held in Brecht v. Abramson, 507 U. S. 619, and O'Neal, supra, that a federal court reviewing a habeas proceeding ordinarily should apply the Kotteakos standard. That standard applies to habeas review of trial errors, including errors in respect to which the Constitution requires state courts to apply a stricter, Chapman-type harmlesserror standard when reviewing a conviction directly. The sort of error
at issue in Carella is a trial error subject to harmless-error analysis. The error at issue here-a misdescription of an element of the crimeis an error of omission, not an error of the structural sort that defies harmless-error analysis.
Certiorari granted; 81 F.3d 863, vacated and remanded.
A California court convicted respondent Kenneth Roy of the robbery and first-degree murder of Archie Mannix. The State's theory, insofar as is relevant here, was that Roy, coming to the aid of a confederate who was trying to rob Mannix, helped the confederate kill Mannix. The trial judge gave the jury an instruction that permitted it to convict Roy of first-degree murder as long as it concluded that (among other things) Roy, "with knowledge of" the confederate's "unlawful purpose" (robbery), had helped the confederate, i. e., had "aid[ed]," "promote[d]," "encourage[d]," or "instigate[d]" by "act or advice ... the commission of" the confederate's crime. The California Supreme Court later held in People v. Beeman, 35 Cal. 3d 547, 561, 674 P. 2d 1318, 1326 (1984), that an identical instruction was erroneous because of what it did not say, namely, that state law also required the jury to find that Roy had the "knowledge [and] intent or purpose of committing, encouraging, or facilitating" the confederate's crime. Id., at 561, 674 P. 2d, at 1326 (emphasis added). Despite this error, the California Court of Appeal affirmed Roy's conviction because it found the error "harmless beyond a reasonable doubt." See Chapman v. California, 386 U. S. 18, 24 (1967). The California Supreme Court denied postconviction relief.
Subsequently Roy, pointing to the same instructional error, asked a Federal District Court to issue a writ of habeas corpus. The District Court denied the request because, in its view, the error was harmless. Indeed, the District Court wrote that no rational juror could have found that Roy knew the confederate's purpose and helped him but also found that Roy did not intend to help him. A divided
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