Calderon v. Coleman

PETITIONER: Calderon
RESPONDENT: Coleman
LOCATION: North Carolina General Assembly

DOCKET NO.: 98-437
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 525 US 141 (1998)
DECIDED: Dec 14, 1998

Facts of the case

During the penalty phase of Russell Coleman's trial, the trial judge gave the jury a "Briggs instruction," explaining the Governor's commutation power. The trial judge then instructed the jury that it was not to consider the Governor's power in reaching its verdict. Ultimately, Coleman sought a federal writ of habeas corpus. The District Court found that, because the Governor may not commute the sentence of a prisoner who, like Coleman, is a twice-convicted felon without the approval of four judges of the California Supreme Court, the Briggs instruction violated the Eighth and Fourteenth Amendments by "giving the jury inaccurate information and potentially diverting its attention from the mitigation evidence presented." In affirming, the Court of Appeals concluded that the giving of the instruction was constitutional error.

Question

Did a court of appeals, in overturning a death sentence due to constitutional errors in the jury instruction, fail to adequately consider whether the errors were "harmless" and made a difference in the final result under Brecht v. Abrahamson?