Supreme Court of the United States

United States v. Hasting

May 23, 1983461 U.S. 499

Summary

The Court held that a reviewing court may not reverse criminal convictions under supervisory authority while avoiding harmless-error analysis for an assumed constitutional violation. On the whole record, the Court concluded beyond a reasonable doubt that the prosecutor's reference to the defense's failure to rebut the evidence did not affect the verdicts. The judgment was reversed and the case remanded for consideration of respondents' remaining claims.

Holding

  • Use of supervisory authority despite potentially harmless constitutional error. A reviewing court may not avoid the constitutionally required harmless-error inquiry by invoking supervisory authority to reverse criminal convictions when the asserted constitutional error may be harmless.
  • Effect of the prosecutor's closing argument. Assuming the prosecutor's remarks constituted a constitutional violation, the error was harmless beyond a reasonable doubt because the evidence of guilt was overwhelming and the defense's evidence was scant and internally inconsistent.

Docket 81-1463

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