Chapman v. California

PETITIONER: Ruth Elizabeth Chapman, Thomas LeRoy Teale
RESPONDENT: California
LOCATION: Former Spot Club Location

DOCKET NO.: 95
DECIDED BY: Warren Court (1965-1967)
LOWER COURT:

CITATION: 386 US 18 (1967)
ARGUED: Dec 07, 1966 / Dec 08, 1966
DECIDED: Feb 20, 1967
GRANTED: Mar 28, 1966

ADVOCATES:
Doris H. Maier - for the respondent
Morris Lavine - for the petitioners
Thomas C. Lynch - for the respondent
Raymond M. Momboisse - for the respondent

Facts of the case

On October 17, 1962, Ruth Elizabeth Chapman and Thomas LeRoy Teale registered at a motel in Fresno, California. At approximately 2:00 A.M. the following day, Chapman and Teale appeared at the Spot Club in Lodi. The only persons at the bar were Teale, Chapman, and the club’s bartender, Billy Dean Adcock. A short time later, a witness observed three persons in front of the Spot Club: a woman of Chapman’s general description and Adcock stood in front of the club’s door, while a man resembling Teale stood behind Adcock while he apparently locked the door.

The next day, the Spot Club’s owner found the club in disarray; someone had broken into the cash register and approximately $260 was missing. Routine housekeeping tasks normally performed by Adcock were left undone. Later, Adcock body’s was found in a remote area north of Lodi, half buried in an open roadside ditch. The time of death was approximately 3:00 AM on October 18th. Adcock was shot three times in the head. The bullets were fired from a .22 caliber weapon similar to one purchased by Chapman while with Teale in Reno, Nevada, six days before the killing. The gun was not found.

Officers arrested Teale in New Orleans on November 2, 1962. He carried a gun purchased the same day as Chapman’s .22 caliber weapon. An agent of the Federal Bureau of Investigation arrested Chapman in St. Joseph, Missouri on October 26, 1962. She gave conflicting accounts of her whereabouts on October 17 and 18, but a registration card from October 18 for occupancy of a motel room in Woodland, California was made out in her handwriting.

Chapman and Teale were charged with the first degree murder of Adcock. A prisoner locked up with Teale testified that Teale did not plan on killing Adcock, but when Chapman and Teale released Adcock from their car outside of Lodi, Chapman shot him once in the back of the head and twice more when he was on the ground. Neither defendant appeared as a witness, but Chapman’s conflicting testimony was introduced by direct examination of the FBI agent. The trial court instructed the jury that they could draw adverse conclusions from the defendants’ failure to testify. The jury convicted both defendants of first degree murder. Shortly thereafter, the Supreme Court held in Griffin v. State of California that California’s practice of allowing prosecutors to use defendants’ silence against them violated the Fifth and Fourteenth Amendments. On appeal, however, the California Supreme Court held that the unconstitutional jury instruction was a harmless error because it did not result in a miscarriage of justice.

Question

(1) Are all federal constitutional errors harmful?

(2) Did it constitute a harmless constitutional error when prosecutors improperly commented on Chapman and Teale’s failure to testify?

Media for Chapman v. California

Audio Transcription for Oral Argument - December 07, 1966 in Chapman v. California

Audio Transcription for Oral Argument - December 08, 1966 in Chapman v. California

Earl Warren:

Number 95, Ruth Elizabeth Chapman and Thomas LeRoy Teale, Petitioners, versus California.

Mr. Smith, you may continue your argument.

Arlo E. Smith:

Mr. Chief Justice, it -- may it please the Court.

Yesterday, we left on the note of why do we look at the entire record.

Under any test regardless of how it is defined it's a question of judgment, its judgmental, as just -- Justice Rutledge said in the Koteakos case, you must examine the entire proceeding.

This case said is Fahy versus Connecticut, you must examine the impact of that error not examine the error alone but the impact of that error upon the entire case to see whether or not it -- in that test, was reasonably possible that it contributed to the conviction.

Doesn't matter how you word it, that's another problem.

That case, there was illegally obtained evidence introduced, the paint in the brushes.

The Court pointed out there that this had a serious impact of the -- the brush marks were identified as being identical with that paint -- painted the swastika.

The paint and the bucket were found in the car which was seen near the scene.

The court pointed out that in fact the confrontation of this illegal evidence probably led to the confession that was introduced.

It pointed to the impact of that testimony upon the defense concluding that it probably brought about the presentation of the defendant, putting the defendant on the stand.

Now what is the impact of a comment hereupon this case?

I suggest to you that there is none when you examine the record in this case.

It had none of these factors that the court pointed to in Fahy.

What happened in this case was a robbery, murder and kidnapping of a bartender in Lodi.

The evidence although the petitioners contend that there was no evidence.

There were three or four exhibits not introduced but the story is a very simple one.

There was conspiracy between Mrs. Chapman and Mr. Teale.

They were seeing together for a period of -- they lived together for a period, they left a city in California on October 10, they went to Reno.

There she purchased a -- which turned out later to be a very peculiar 22 automatic, and a 32.

Thereafter they were registered jointly in a motel in Fresno not 100 miles below the scene of the crime, the very day before the robbery, kidnapping and murder.

He signed the registration, she signed would turned out to be a bad check.

They were identified.

There was expert testimony all the way through as to the signatures.

Thereafter that evening, they were seen in a bar called -- bar and restaurant called Croce's in City of Lodi.

They were there from about ten until shortly after one o'clock.

There were various things that occurred there, there was a lot of discussions but they were positively identified there.

They were positively established that they were driving the same 61 Ford that's -- goes throughout the proceedings.

Abe Fortas:

Are you inviting us to --