| Court: | US Supreme Court |
| Facts: | Some guys rob a man named Stafford. They also take his clothes off and leave him by the roadside in winder. Plus, this guy was very drunk. He gets out in the road, without his glasses, and gets run over. |
| Posture: | Convicted of second-degree murder at trial. Affirmed at the Appellate division, and at the Court of Appeals. Then Federal District Court, which found the issue non-reviewable. The court of appeals for the second district then reversed, and presumably the state appealed from that point. Good grief. The murder charge is the basis of the appeal, although the defendants were also convicted of robbing the guy. |
| Issue: | Does a NY court judge's failure to instruct on causation at trial warrant Federal habeas corpus relief? |
| Holding: | The absence of this instruction is very unlikely to have prejudiced the jury in this case, so there was no constitutional error. |
| Rule: | In order to grant relief, there must both be error, and the error has to have been likely to affect the outcome. |
| Reasoning: | Due Process requires proof beyond reasonable doubt. The evidence supports a finding that the defendant's caused the victim's death. And the hury did find thusly. So Winship doesn't help here. Also, no erroneous instruction was given, and nobody even noticed this until the intermediate appellate level, so it's unlikely that it was a big factor with the jury. Therefore there was no harm. |
| Dicta: | It is rare for improper jury instructions to justify a reversal when no objection is raised at trial. |