Case Citator › Yates v. Evatt

Yates v. Evatt

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Supreme Court of the United States
Citation
500 U.S. 391
Decided
Confirmed treatments
2
Flagged citations read
106 of 107
Citing cases (total)
930
Treatment dates
1991–1993
Overruled in part
A reviewed court has overruled part of this case’s holding. Yates v. Evatt has 2 confirmed treatments listed below after review of all 107 flagged citations. Direct review confirms that Estelle v. McGuire displaced Yates's phrasing for reviewing ambiguous jury instructions and that Brecht v. Abrahamson rejected the Chapman harmless-error standard that Yates had assumed on federal habeas review.
More on how this was screened

The other available opinions applied unaffected Yates rules, directed nearby treatment language at other authorities, or copied history parentheticals reporting another court's act; the text of one citing opinion could not be retrieved, as noted below, so it remains unread.

The treatments below are confirmed; unread citations could still change the overall status.
Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case, except the ones whose text could not be retrieved.

930 later cases cite Yates v. Evatt; 107 of those citations sat close to treatment language and were flagged for reading; 106 of them have been read, and the text of 1 citing opinion could not be retrieved, so it remains unread. 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 Yates v. Evatt?

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

Overruled in Part

  • The Supreme Court disapproved Yates's “could have” or “would have” phrasing for reviewing jury instructions and reaffirmed the “reasonable likelihood” standard.

    Estelle v. McGuire · Supreme Court of the United States · filed

    We acknowledge that language in the later cases of Cage v. Louisiana, 498 U. S. 39 (1990), and Yates v. Evatt, 500 U. S. 391 (1991), might be read as endorsing a different standard of review for jury instructions. ... So that we may once again speak with one voice on this issue, we now disapprove the standard of review language in Cage and Yates, and reaffirm the standard set out in Boyde.
    Read the full opinion on CourtListener →

Abrogated

  • The Supreme Court abrogated Yates's assumed use of Chapman's harmless-beyond-a-reasonable-doubt standard on federal habeas review, replacing it with the less onerous Kotteakos standard.

    Brecht v. Abrahamson · Supreme Court of the United States · filed

    Although we have applied the Chapman standard in a handful of federal habeas cases, see, e. g., Yates v. Evatt, 500 U. S. 391 (1991); Rose v. Clark, 478 U. S. 570 (1986); Milton v. Wainwright, 407 U. S. 371 (1972); Anderson v. Nelson, 390 U. S. 523 (1968) (per curiam), we have yet squarely to address its applicability on collateral review. ... But since we have never squarely addressed the issue, and have at most assumed the applicability of the Chapman standard on habeas, we are free to address the issue on the merits. ... For the foregoing reasons, then, we hold that the Kotteakos harmless-error standard applies in determining whether habeas relief must be granted because of constitutional error of the trial type.
    Read the full opinion on CourtListener →

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