Weaver v. Massachusetts

137 S.Ct. 1899 (2017)

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Nature of the Case

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Facts

A 15-year-old boy was shot and killed in Boston. A witness saw a young man fleeing the scene of the crime and saw him pull out a pistol. A baseball hat fell off his head. The police recovered the hat, which featured a distinctive airbrushed Detroit Tigers logo on either side. The hat’s distinctive markings linked it to 16-year-old Kentel Weaver (D). DNA obtained from the hat matched D’s DNA. D admitted losing his hat around the time of the shooting but denied being involved. D's mother got involved and forced him to confess. D was indicted for first-degree murder. D pleaded not guilty and proceeded to trial. The pool of potential jury members was 60 to 100 people. The assigned courtroom could accommodate only 50 or 60 in the courtroom seating. There was simply not enough space in the courtroom for everybody. An officer of the court excluded from the courtroom any member of the public who was not a potential juror. So, when D’s mother and her minister came to the courtroom to observe the two days of jury selection, they were turned away. This occurred before Presley v. Georgia. D’s mother told counsel, but counsel thought closure for jury selection was constitutional. P presented strong evidence of D’s guilt. D was convicted. Five years later, D filed a motion for a new trial arguing ineffective assistance by failing to object to the courtroom closure. The trial court determined that defense counsel failed to object because of “serious incompetency, inefficiency, or inattention.” But it also determined that D had not offered any evidence or legal argument establishing prejudice. It denied a new trial. D appealed, and the court affirmed; Although it recognized that “a violation of the Sixth Amendment right to a public trial constitutes structural error,” the court stated that petitioner had “failed to show that trial counsel’s conduct caused prejudice warranting a new trial.” The Supreme Court granted certiorari to resolve the conflicts regarding proof needed.