Supreme Court of the United States
Harris v. Rivera
December 4, 1981454 U.S. 339
Summary
The Court held that facially inconsistent verdicts in a non‑jury state bench trial do not, by themselves, violate the Fourteenth Amendment’s Due Process Clause, and therefore federal habeas relief was unavailable. The decision reversed the Second Circuit and affirmed the state convictions, noting that a trial judge is not required to explain such inconsistencies. Justice Marshall dissented, criticizing the Court’s summary disposition practice.
Holding
- Whether a facially inconsistent bench‑trial verdict in a state criminal case violates the Fourteenth Amendment’s Due Process Clause and thus warrants federal habeas relief. No; inconsistency alone does not create a constitutional defect, and a federal court may not require a state trial judge to explain the inconsistency.
Docket 81-17
Cited authorities
Cited by
- Commonwealth v. James Robicheau
- Commonwealth v. Nelson Gonzalez (and five companion cases)
- United States v. Milton Eugene Robins
- United States of America, Appellee v. Marie v. Cyr, Defendant, Appellant
- James P. Merchant, Plaintiff, Appellee v. Philip Henry Ruhle, Defendant, Appellant
- United States of America, Appellee v. William Crooks A/k/a “billy,” Defendant, Appellant
- United States of America, Appellee v. Hector Alfredo Viceconte Paone, Defendant, Appellant
- United States, Appellee v. George Bucuvalas, Defendant, Appellant