Weaver v. Massachusetts

Supreme Court of the United States
582 U. S. ____ (2017) (2017)

ELI5:

Rule of Law:

When a defendant raises a claim of ineffective assistance of counsel based on the failure to object to a structural error, such as a public trial violation, the defendant is not entitled to automatic reversal. The defendant must still satisfy the prejudice prong of the Strickland test by showing either a reasonable probability of a different outcome or that the error rendered the trial fundamentally unfair.

Facts:

In 2003, a 15-year-old boy was shot and killed in Boston.
Police recovered a distinctive baseball hat at the scene, which was linked to 16-year-old Kentel Weaver through its unique markings and a DNA match.
When Weaver's mother questioned him, he admitted to being at the scene of the crime.
When she asked if he was the shooter, Weaver put his head down and remained silent, which she interpreted as an admission of guilt.
Weaver's mother insisted he confess to the police, which he subsequently did.
During jury selection for Weaver's murder trial, the courtroom was too small to accommodate the entire jury pool.
As a result, a court officer excluded all members of the public, including Weaver's mother and her minister, from the courtroom for two days during jury selection.
Weaver's mother informed his defense counsel of the closure, but counsel failed to object, believing at the time that such a closure was constitutional.

Procedural Posture:

Kentel Weaver was convicted of first-degree murder and a handgun offense in a Massachusetts state trial court.
Five years after his conviction, Weaver filed a motion for a new trial in the trial court, alleging ineffective assistance of counsel for his attorney's failure to object to the courtroom closure during jury selection.
The trial court found counsel's performance was deficient but denied the motion, ruling that Weaver had failed to establish prejudice.
Weaver appealed the denial to the Massachusetts Supreme Judicial Court, the state's highest court.
The Massachusetts Supreme Judicial Court affirmed the trial court's decision, agreeing that Weaver had not shown the required prejudice for an ineffective assistance of counsel claim.
The U.S. Supreme Court granted certiorari to resolve a conflict among lower courts on this issue.

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Issue:

Does a defendant who raises a structural error (a violation of the right to a public trial) via an ineffective assistance of counsel claim need to satisfy the Strickland prejudice requirement to obtain a new trial?

Opinions:

Majority - Justice Kennedy

Yes. A defendant who raises a public trial violation through an ineffective assistance of counsel claim is not entitled to automatic reversal and must demonstrate prejudice under Strickland v. Washington. The automatic reversal rule for structural errors applies when the error is preserved at trial and raised on direct appeal. However, when the claim is framed as one of ineffective assistance, the defendant must satisfy Strickland's two-prong test: deficient performance and prejudice. The Court reasons that the finality of convictions is a major concern in post-conviction proceedings. Furthermore, a violation of the Sixth Amendment right to effective counsel is not 'complete' until the defendant is prejudiced. While a public trial violation is a structural error, it is classified as such because its effects are difficult to measure, not because it renders every trial fundamentally unfair. Therefore, to show prejudice in this context, the defendant must demonstrate either a reasonable probability that the outcome would have been different, or that the specific closure was so serious that it rendered the trial fundamentally unfair. In this case, Weaver failed to make either showing.

Concurring - Justice Thomas

Yes. Justice Thomas joins the majority but writes separately to express doubt about whether the Sixth Amendment's public trial right extends to jury selection, suggesting Presley v. Georgia should be reconsidered. He also questions the majority's assumption that 'fundamental unfairness' is a separate way to establish Strickland prejudice, arguing the proper test is whether there is a reasonable probability that the trial's result would have been different, which focuses on the reliability of the outcome.

Concurring - Justice Alito

Yes. The case requires a straightforward application of Strickland v. Washington. The 'structural error' label is irrelevant when analyzing an ineffective assistance of counsel claim. The prejudice prong of Strickland does not ask if an error was harmless, but whether a Sixth Amendment violation occurred at all, which requires a showing of prejudice. A defendant must show a reasonable probability that, but for counsel's error, the result of the proceeding would have been different. Weaver failed to make this showing, and therefore his claim fails.

Dissenting - Justice Breyer

No. A defendant whose counsel's deficient performance resulted in a structural error should not have to make an additional showing of prejudice under Strickland. The very reason an error is deemed 'structural' is that its effects on the trial's outcome are unquantifiable and defy harmless-error analysis. To require a defendant to prove prejudice from an error whose effects are 'too hard to measure' is to require the impossible. Therefore, when an attorney's deficient performance causes a structural error, prejudice should be presumed, and the defendant should be entitled to relief.

Analysis:

This decision significantly clarifies the intersection of structural errors and ineffective assistance of counsel claims, prioritizing the finality of judgments. By refusing to presume prejudice, the Court makes it substantially more difficult for defendants to succeed on post-conviction claims based on un-objected-to trial errors, even serious ones like courtroom closures. The ruling reinforces that the Strickland prejudice standard is a robust requirement that is not easily overcome, even when the underlying error is 'structural.' This holding requires lower courts to differentiate between structural errors raised on direct appeal versus those raised collaterally, applying a much stricter standard to the latter.

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