Chapman v. California

386 U.S. 18 (1967)

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Nature of the Case

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Facts

Chapman (D) and Teale, were convicted of robbery, kidnapping, and murder of a bartender. D was sentenced to life imprisonment and Teale to death. The State's Constitution provided that 'in any criminal case, whether the defendant testifies or not, his failure to explain or to deny by his testimony any evidence or facts in the case against him may be commented upon by the court and by counsel, and may be considered by the court or the jury.' Ds chose not to testify at their trials, and the State took full advantage to comment upon their failure to testify. The trial court also charged the jury that it could draw adverse inferences from Ds' failure to testify. In Griffin v. California, 380 U.S. 609, the court held this constitutional provision and practice invalid on the ground that they put a penalty on the exercise of a person's right not to be compelled to be a witness against himself, guaranteed by the Fifth Amendment to the United States Constitution and made applicable to California and the other States by the Fourteenth Amendment. The State Supreme Court then heard Ds' appeals and admitted that they had been denied a federal constitutional right by the comments on their silence. It affirmed applying the State Constitution's harmless-error provision, which forbids reversal unless 'the court shall be of the opinion that the error complained of has resulted in a miscarriage of justice.' The Supreme Court granted certiorari.