Brecht v. Abrahamson

Brecht (plaintiff) shot and killed his brother-in-law, then fled, and was later arrested and read his Miranda rights; at trial he claimed the shooting was accidental, and the prosecution repeatedly emphasized on cross-examination that he had never claimed it was an accident before trial — a use of his post-Miranda silence that violated Doyle v. Ohio. Brecht was convicted of first-degree murder; state appellate courts disagreed over whether the Doyle violation was harmless, with the state supreme court applying the stricter Chapman "harmless beyond a reasonable doubt" test and finding it was. On federal habeas, the district court again set aside the conviction under Chapman, but the court of appeals reversed, holding a different, less exacting standard should apply on collateral review; the Supreme Court granted certiorari.