Term: 2008
Docket: 07-544
Anthony Hedgpeth, Warden v. Michael Robert Pulido
- Pro
07-544 HEDGPETH V. PULIDO DECISION BELOW: 487 F3d 669 CERT. GRANTED 2/25/2008 QUESTION PRESENTED: Stromberg v. California, 283 U.S. 359 (1931), required the reversal of the judgment if a general verdict could have rested on an instruction that defined a constitutionally defective alternative theory of criminal liability. However, a modern line of cases, including Neder v. United States, 527 U.S. 1 (1999), establishes that error in instructing on an element of a charged crime is not “structural error,” so as to require automatic reversal, but is instead “trial error” and, as such, may be harmless. The question presented is: Did the Ninth Circuit fail to conform to “clearly established” Supreme Court law, as required by 28 U.S.C. § 2254(d), when it granted habeas corpus relief by deeming an erroneous instruction on one of two alternative theories of guilt to be “structural error” requiring reversal because the jury might have relied on it? LOWER COURT CASE NUMBER: 05-15916, 05-16308
In the case of Anthony Hedgpeth, Warden v. Michael Robert Pulido (2008), the U.S. Supreme Court ruled on an issue related to jury instructions in a criminal trial. The respondent, Michael Pulido, was convicted for felony murder and robbery based on evidence that he aided and abetted his uncle during these crimes. However, the jury instruction given at his trial allowed conviction if they found him guilty either as an aider or abettor or if they believed he formed intent to aid after the crime had already been committed - which is not sufficient under California law for a felony-murder charge. On appeal, it was argued this constituted a "structural error" requiring automatic reversal of his conviction because it violated due process by allowing jurors to convict without unanimous agreement on guilt theory. The Supreme Court disagreed with this argument stating that such errors are subject to harmless-error analysis – meaning courts must determine whether error affected outcome before deciding whether new trial is warranted – rather than being automatically reversible.
In the dissenting opinion for Anthony Hedgpeth, Warden v. Michael Robert Pulido, Justice John Paul Stevens argued that the majority's decision to uphold Pulido's conviction despite a potentially misleading jury instruction was incorrect. He contended that this ruling contradicted previous Supreme Court decisions which held that convictions should be overturned if there is reasonable likelihood that jurors misunderstood or misapplied instructions in ways affecting verdicts. In his view, it was reasonably likely jurors could have mistakenly believed they could convict Pulido of felony murder even if he formed intent to rob after killing occurred - an interpretation inconsistent with California law and thus violating due process rights. Furthermore, he criticized the majority’s application of harmless-error review as inappropriate because it failed to consider whether erroneous instruction might have contributed to verdict within context of entire trial record.
