Law School Case Brief
Henderson v. Kibbe - 431 U.S. 145
In a habeas petition, the burden of demonstrating that an erroneous instruction was so prejudicial that it supports a collateral attack on the constitutional validity of a state court's judgment is even greater than the showing required to establish plain error on direct appeal. The question in such a collateral proceeding is whether the ailing instruction by itself so infected the entire trial that the resulting conviction violates due process, not merely whether the instruction is undesirable, erroneous, or even universally condemned.
Respondent prisoner was convicted of second degree murder after he robbed a man and left him on a deserted road in a snowstorm without his glasses or protective clothing, only to have the man killed when he was hit by a car. The prisoner challenged the conviction, alleging that the trial court's failure to instruct the jury on the issue of causation was constitutional error. The state appellate court and state supreme court affirmed the prisoner's conviction, and he sought federal habeas corpus relief. The federal appellate court granted the prisoner's request and petitioner prison official appealed the decision of the United States Court of Appeals for the Second Circuit, which reversed the district court's denial of respondent prisoner's petition for habeas corpus, filed pursuant to 28 U.S.C.S. § 2254.
Did the trial court's failure to instruct the jury on the statutory issue of causation (the defendants having neither requested such an instruction nor objected to its omission) constitute constitutional error violative of due process standards requiring proof beyond a reasonable doubt of every element of the offense?
The judgment of the appellate court was reversed. The Court held that (1) the trial court sufficiently instructed the jury on the issue of causation, (2) the evidence was sufficient to support the jury's verdict; and (3) prisoner failed to meet the heightened burden of demonstrating that an erroneous instruction was so prejudicial that it would support a collateral attack on the constitutionality of his conviction. The burden of demonstrating this prejudice was greater than the showing required to establish plain error on direct appeal, particularly because prisoner failed to object to the lack of a jury instruction at trial.
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