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Brecht Vs. Abrahamson
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- US Supreme Court
- Apr 21, 1993
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aside on the grounds that the State's references to his post-Miranda silence violated due process under Doyle v. OhioSearch
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under the standard set forth in Chapman v. CaliforniaSearch
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reversing, the Court of Appeals held that the proper standard of harmless-error review was that set forth in Kotteakos v. UnitedSearch
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See Arizona v. FulminanteSearch
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resulted. See United States v. LaneSearch
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CHIEF JUSTICE REHNQUIST delivered the opinion of the Court. In Chapman v. CaliforniaSearch
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s use for impeachment purposes of petitioner's post-Miranda 1 silence, in violation of due process under Doyle v. OhioSearch
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Kotteakos v. UnitedSearch
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Hartman returned home from work, petitioner shot him in the back and sped off in Mrs. Hartman's car. 1 Miranda v. ArizonaSearch
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State's references to petitioner's post-Miranda silence, see n. 2, supra, violated due process under Doyle v. OhioSearch
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to require reversal. State v. BrechtSearch
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State v. BrechtSearch
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Wis. 2d 297, 317, 421 N. W. 2d 96, 104 (1988) (quoting Chapman v. CaliforniaSearch
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F. 2d, at 1375 (quoting Kotteakos v. UnitedSearch
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and the confusion which would ensue were we to adopt the Kotteakos harmless-error standard on 3 Cf. Bass v. NixSearch
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considering these arguments, however, we must first characterize the nature of Doyle error itself. In Doyle v. OhioSearch
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U. S. 284 , 291 (1986) (quoting South Dakota v. NevilleSearch
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the Constitution does not prohibit the use for impeachment purposes of a defendant's silence prior to arrest, Jenkins v. AndersonSearch
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U. S. 231 , 239 (1980), or after arrest if no Miranda warnings are given, Fletcher v. WeirSearch
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tJ''' them. Duckworth v. EaganSearch
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of such defects-deprivation of the right to counsel,4 for example-requires automatic reversal of the 4 Gideon v. WainwrightSearch
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because they infect the entire trial process. See id., at 309-310. Since our landmark decision in Chapman v. CaliforniaSearch
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standard. Although we have applied the Chapman standard in a handful of federal habeas cases, see, e. g., Yates v. EvattSearch
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per curiam), we have yet squarely to address its applicability on collateral review.6 5 Griffin v. CaliforniaSearch
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U. S. 609 (1965). 6 In Greer v. MillerSearch
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the applicability of the Chapman standard on habeas, we are free to address the issue on the merits. See Edelman v. JordanSearch
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have limited its application to claims of nonconstitutional error in federal criminal cases. See, e. g., United States v. LaneSearch
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Schneidewind v. ANRSearch
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Pipeline Co., 485 U. S. 293 , 306 (1988) (citing American Trucking Assns., Inc. v. AtchisonSearch
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more amenable to harmless-error review of constitutional violations. Cf. United States v. HastingSearch
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Red Lion Broadcasting Co. v. FCCSearch
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claim. We have filled the gaps of the habeas corpus statute with respect to other matters, see, e. g., McCleskey v. ZantSearch
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Sanders v. UnitedSearch
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collateral review is different from direct review resounds throughout our habeas jurisprudence. See, e. g., Wright v. WestSearch
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Mackey v. UnitedSearch
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