Chapman v. California
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
The Louisiana Supreme Court separately confined Chapman's use for improper prosecutorial argument. The other opinions applied Chapman, distinguished structural errors, reported Brecht's act, or used treatment language for unrelated authorities.
22,958 later cases cite Chapman v. California; 566 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Chapman v. California?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Limited
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The Supreme Court confined Chapman's harmless-beyond-a-reasonable-doubt rule to direct review and adopted the less onerous substantial-and-injurious-effect standard for federal habeas review of trial error.
Brecht v. Abrahamson · Supreme Court of the United States · filed
The Kotteakos harmless-error standard is better tailored to the nature and purpose of collateral review than the Chapman standard, and application of a less onerous harmless-error standard on habeas promotes the considerations underlying our habeas jurisprudence.
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The Louisiana Supreme Court limited Chapman to prosecutorial comments presenting inadmissible unsworn facts outside the record and used a more deferential standard for other improper closing argument.
State v. Sanders · Supreme Court of Louisiana · filed
This court has recently held that the harmless error standard of Chapman v. California, 386 U.S. 18, 24, 87 S.Ct. 824, 828, 17 L.Ed.2d 705 (1967), should "also apply to the erroneous and improper arguments of a prosecutor...." ... However, the court limited the application of the Chapman rule to prosecutorial comments which "present to the jury [the prosecutor's] inadmissible unsworn testimony to facts outside the record...." ... Thus, this opinion will apply the older and more deferential "thoroughly convinced" standard of Byrne, Jarman, and Messer.
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The en banc Tenth Circuit held that Brecht, not Chapman, governs federal habeas harmlessness even when the state court failed to perform Chapman review.
Herrera v. Lemaster · Tenth Circuit (en banc) · filed
After AEDPA, when a state court decides a constitutional issue ... contrary to Supreme Court authority, or unreasonably applies Supreme Court authority, should the habeas court on collateral review apply the harmless error standard of Chapman v. California, 386 U.S. 18 (1967), to assess the constitutional violation, or should it apply the standard set out in Brecht v. Abrahamson, 507 U.S. 619 (1993). ... Upon en banc consideration, we hold that the standard set out in Brecht is the appropriate one to use in these circumstances.
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The Supreme Court further confined Chapman by holding that Brecht governs Section 2254 proceedings even when the state appellate court did not recognize the error or conduct Chapman review.
Fry v. Pliler · Supreme Court of the United States · filed
We hold that in §2254 proceedings a court must assess the prejudicial impact of constitutional error in a state-court criminal trial under the “substantial and injurious effect” standard set forth in Brecht, supra, whether or not the state appellate court recognized the error and reviewed it for harmlessness under the “harmless beyond a reasonable doubt” standard set forth in Chapman, 386 U. S. 18. Since the Ninth Circuit correctly applied the Brecht standard rather than the Chapman standard, we affirm the judgment below.
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The Supreme Court further confined harmless-error relief on federal habeas by requiring a prisoner to satisfy both Brecht's Chapman-adapted collateral-review test and AEDPA.
Brown v. Davenport · Supreme Court of the United States · filed
Brecht sought to adapt Chapman’s harmless-error rule, developed for cases on direct appellate review, for use in federal habeas proceedings. ... Rather than require the prosecution to prove that a constitutional trial error is harmless, Brecht held that a state prisoner seeking to challenge his conviction in collateral federal proceedings must show that the error had a “ ‘substantial and injurious effect or influence’ ” on the outcome of his trial. ... But in cases like ours satisfying Brecht is only a necessary, not a sufficient, condition to relief. AEDPA too must be satisfied. The Sixth Circuit erred in holding otherwise.
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Does this case still carry your argument?
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