## Facts

- Ruth Elizabeth Chapman and Thomas LeRoy Teale were tried in California for robbery, kidnapping, and first-degree murder.
- Neither defendant testified at trial.
- California law at the time permitted the prosecutor and court to comment on a defendant’s failure to testify and allowed jurors to treat silence as evidence of guilt.
- The prosecutor repeatedly argued that defendants’ silence supported an inference of guilt, and the trial court instructed the jury it could draw adverse inferences from the failure to testify.
- After trial but before the state appeal was decided, the U.S. Supreme Court held that adverse comment on a defendant’s silence violates the Fifth Amendment as applied to the states.

## Issues

1. Whether a state court may apply its own harmless-error rule to affirm convictions despite a violation of a federal constitutional right.
2. What standard governs harmless-error review for federal constitutional errors.
3. Whether the prosecutor’s comments and the trial court’s instruction about defendants’ silence were harmless under the correct standard.

## Decision

- The U.S. Supreme Court reversed the judgments affirming the convictions.
- The Court held that harmless-error review for violations of federal constitutional rights is governed by a federal standard, not by a state harmless-error provision.
- The Court adopted the rule that a constitutional error is harmless only if the reviewing court can conclude it was harmless beyond a reasonable doubt.
- Applying that rule, the Court held the State did not show beyond a reasonable doubt that the repeated comments on silence and the adverse-inference instruction did not contribute to the verdict.

## Legal Principles

- Violations of federally protected constitutional rights in state criminal trials are subject to a federal harmless-error rule.
- A constitutional error may be treated as harmless only when the State proves beyond a reasonable doubt that the error did not contribute to the conviction.
- Even where evidence of guilt is substantial, repeated prosecutorial reliance on a defendant’s silence and a court instruction authorizing adverse inferences can defeat a harmlessness showing.

## Conclusion

Chapman requires state courts reviewing federal constitutional trial errors to apply a uniform federal harmless-error test and to affirm only when the State establishes beyond a reasonable doubt that the error did not affect the verdict.


Chapman v. California, 386 U.S. 18 (1967)