Weaver v. Massachusetts
137 S. Ct. 1899
| SCOTUS | 2017Background
- Kentel Weaver (age 16 at time) was tried in Massachusetts for murder and illegal gun possession; conviction rested on hat DNA and a confession.
- During two days of jury selection the courtroom was filled with potential jurors and closed to the public; Weaver’s mother and her minister were excluded.
- Defense counsel knew of the exclusion but did not object at trial or raise the issue on direct appeal; years later Weaver moved for a new trial claiming ineffective assistance for failure to object.
- Massachusetts trial court and the state supreme court found a Sixth Amendment public‑trial violation (structural error) but rejected relief because Weaver failed to show prejudice from counsel’s omission.
- The U.S. Supreme Court granted certiorari to decide whether a defendant who raises a preserved structural error only via an ineffective‑assistance claim must show prejudice to obtain relief.
Issues
| Issue | Plaintiff's Argument (Weaver) | Defendant's Argument (Massachusetts) | Held |
|---|---|---|---|
| Whether a public‑trial violation raised in an ineffective‑assistance claim requires a showing of prejudice | Weaver: counsel’s failure to object to closure was ineffective; structural error should entitle him to automatic reversal or at least relief without ordinary prejudice showing | State: when a structural error is not preserved and is raised later via Strickland, defendant must show prejudice before getting a new trial | Held: Defendant raising closure via ineffective‑assistance must prove prejudice—either a reasonable probability of a different outcome or that the violation rendered the trial fundamentally unfair |
| Proper interaction of structural‑error doctrine with Strickland prejudice prong | Weaver: structural status should avoid need for Strickland prejudice showing because effects are hard to measure | State: finality and differences between direct appeal and collateral review justify requiring prejudice on ineffective‑assistance claims | Held: Structural error status does not eliminate Strickland prejudice requirement on collateral review; reasons include lost chance to cure, finality interests, and evidentiary difficulties |
| Whether the specific facts here show Strickland prejudice or fundamental unfairness | Weaver: exclusion of family likely affected jury behavior; constitutes fundamental unfairness | State: record shows closure limited to voir dire, transcript exists, many venirepersons observed, no misconduct, strong evidence of guilt | Held: Weaver failed to show a reasonable probability of a different outcome and did not demonstrate fundamental unfairness; no new trial granted |
| Scope of precedents that require automatic reversal when preserved on direct review | Weaver: structural rulings recognize some errors are per se prejudicial | State: those precedents remain intact for preserved errors on direct review; this case concerns collateral Strickland context | Held: Court reaffirmed direct‑review automatic reversal precedents but limited their application on collateral ineffective‑assistance claims, requiring prejudice proof |
Key Cases Cited
- Chapman v. California, 386 U.S. 18 (harmless‑error standard; government must show error did not contribute to verdict)
- Strickland v. Washington, 466 U.S. 668 (ineffective‑assistance: deficient performance and prejudice required)
- Presley v. Georgia, 558 U.S. 209 (public‑trial right extends to jury selection)
- Waller v. Georgia, 467 U.S. 39 (standards for courtroom closure; closures rare and must be justified)
- United States v. Gonzalez‑Lopez, 548 U.S. 140 (structural errors and rationale; some errors not amenable to harmless‑error review)
- Neder v. United States, 527 U.S. 1 (automatic reversal for certain preserved structural errors)
- Arizona v. Fulminante, 499 U.S. 279 (characterization of structural vs. trial errors)
- Gideon v. Wainwright, 372 U.S. 335 (right to counsel as structural error when denied)
- Sullivan v. Louisiana, 508 U.S. 275 (reasonable‑doubt instruction error as structural)
- Cronic v. United States, 466 U.S. 648 (circumstances where prejudice presumed for counsel deprivation)