Cite as: 519 U. S. 2 (1996)
Per Curiam
at issue in Carella is a trial error subject to harmless-error analysis. The error at issue here—a misdescription of an element of the crime— is an error of omission, not an error of the structural sort that defies harmless-error analysis.
Certiorari granted; 81 F. 3d 863, vacated and remanded.
Per Curiam.
A California court convicted respondent Kenneth Roy of the robbery and first-degree murder of Archie Mannix. The State's theory, insofar as is relevant here, was that Roy, coming to the aid of a confederate who was trying to rob Mannix, helped the confederate kill Mannix. The trial judge gave the jury an instruction that permitted it to convict Roy of first-degree murder as long as it concluded that (among other things) Roy, "with knowledge of" the confederate's "unlawful purpose" (robbery), had helped the confederate, i. e., had "aid[ed]," "promote[d]," "encourage[d]," or "instigate[d]" by "act or advice . . . the commission of" the confederate's crime. The California Supreme Court later held in People v. Beeman, 35 Cal. 3d 547, 561, 674 P. 2d 1318, 1326 (1984), that an identical instruction was erroneous because of what it did not say, namely, that state law also required the jury to find that Roy had the "knowledge [and] intent or purpose of committing, encouraging, or facilitating" the confederate's crime. Id., at 561, 674 P. 2d, at 1326 (emphasis added). Despite this error, the California Court of Appeal affirmed Roy's conviction because it found the error "harmless beyond a reasonable doubt." See Chapman v. California, 386 U. S. 18, 24 (1967). The California Supreme Court denied postconviction relief.
Subsequently Roy, pointing to the same instructional error, asked a Federal District Court to issue a writ of habeas corpus. The District Court denied the request because, in its view, the error was harmless. Indeed, the District Court wrote that no rational juror could have found that Roy knew the confederate's purpose and helped him but also found that Roy did not intend to help him. A divided
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