Brecht v. Abrahamson, 507 U.S. 619, 33 (1993)

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Cite as: 507 U. S. 619 (1993)

O'Connor, J., dissenting

former practice of applying it to cases on habeas and direct review alike. See ante, at 630. I therefore respectfully dissent.

The Court begins its analysis with the nature of the constitutional violation asserted, ante, at 628-630, and appropriately so. We long have recognized that the exercise of the federal courts' habeas powers is governed by equitable principles. Fay v. Noia, supra, at 438; Withrow, post, at 699-700 (O'Connor, J., concurring in part and dissenting in part). And the nature of the right at issue is an important equitable consideration. When a prisoner asserts the violation of a core constitutional privilege critical to the reliability of the criminal process, he has a strong claim that fairness favors review; but if the infringement concerns only a prophylactic rule, divorced from the criminal trial's truthfinding function, the prisoner's claim to the equities rests on far shakier ground. Thus, in Withrow v. Williams, this Court declined to bar relitigation of Miranda claims on habeas because Miranda is connected to the Fifth Amendment and the Fifth Amendment, in turn, serves the interests of reliability. Wi-throw, post, at 691-692. I dissented because I believe that Miranda is a prophylactic rule that actually impedes the truthseeking function of criminal trials. Withrow, post, at 700, 701-708. See also Stone v. Powell, supra, at 486, 490 (precluding review of exclusionary rule violations in part because the rule is judicially fashioned and interferes with the truthfinding function of trial).

Petitioner in this case alleged a violation of Doyle v. Ohio, 426 U. S. 610 (1976), an error the Court accurately characterizes as constitutional trial error. Ante, at 629-630. But the Court's holding today, it turns out, has nothing to do with Doyle error at all. Instead, the Court announces that the harmless-error standard of Chapman v. California, 386 U. S. 18, 24 (1967), which requires the prosecution to prove constitutional error harmless beyond a reasonable doubt, no longer applies to any trial error asserted on habeas, whether it is a

651

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