Brecht v. Abrahamson

How later courts described this case

• holding that the Chapman harmless error standard, which requires the court to ask if absent the improperly admitted evidence, it is clear beyond a reasonable doubt that the jury would have returned a verdict of guilty, was not appropriate when reviewing habeas petitions, and replacing it with the lesser harmless-error standard articulated in Kotteakos v. United States, 328 U.S. 750, 776, 66 S.Ct. 1239, 90 L.Ed. 1557 (1946)
• holding that “granting habeas relief merely because there is a ‘reasonable possibility’ that trial error contributed to the verdict” is inappropriate on collateral review, where the actual-prejudice standard is “better tailored to the nature and purpose of collateral review and more likely to promote the considerations underlying . . . habeas cases,” such as finality (quoting Chapman v. California, 386 U.S. 18, 24 (1967))
• holding that, although the Court had applied the harmless-error standard set forth in Chapman v. California , 386 U.S. 18 , 87 S.Ct. 824 , 17 L.Ed.2d 705 (1967), to "a handful of federal habeas cases," it was not bound to the conclusion that harmless error applied to collateral review because it had not "squarely addressed the issue, and ... at most assumed the applicability of the Chapman standard on habeas"
• holding that the “less onerous” substantial-and-injurious harmless error standard established by Kotteakos v. U.S., 328 U.S. 750, 776, 66 S.Ct. 1239, 90 L.Ed. 1557 (1946) is better tailored to the nature and purpose of collateral review than the “harmless beyond a reasonable doubt” standard established by Chapman v. California, 386 U.S. 18, 24, 87 S.Ct. 824, 17 L.Ed.2d 705 (1967)

Written by the judges who cited it.