Brecht v. Abrahamson
Significance: When federal courts review challenges to trial errors involving Miranda violations, the Supreme Court held that the courts may overturn convictions only when the errors result in “a substantial and injurious effect or influence” on the outcome of the trial.
In a trial that resulted in Todd Brecht's conviction on charges of first-degree murder, the prosecutor made statements that were contrary to the Supreme Court's binding interpretations of Miranda v. Arizona (1966). The Court had previously held that the state had the burden of proving beyond a reasonable doubt that any constitutional error was harmless. In Brecht, a 5-4 majority of the Court voted to expand the “harmless error” standard in cases involving Miranda rights. Chief Justice William H. Rehnquist's opinion for the majority had the result of shifting the burden of proof from the state to the defendant filing a petition for a habeas corpus hearing in federal court.