Supreme Court of the United States
Rivera v. Illinois
March 31, 2009556 U.S. 148
Summary
Justice Ginsburg, writing for a unanimous Court, held that a state trial court’s good-faith erroneous denial of a peremptory challenge does not violate federal due process when the defendant receives a fair trial before qualified, unbiased jurors. Because peremptory challenges are not constitutionally required, federal law does not require automatic reversal in these circumstances; states may determine whether the error requires reversal or permits harmless-error review. The Court affirmed the Illinois Supreme Court’s judgment upholding Rivera’s conviction. There were no separate opinions.
Holding
- Whether the erroneous denial of Rivera’s peremptory challenge violated federal due process.. The good-faith erroneous denial of a state-provided peremptory challenge does not violate federal due process when the defendant is tried fairly before a qualified and impartial jury.
- Whether federal law required automatic reversal notwithstanding the absence of a constitutional violation.. Federal law does not require automatic reversal for the mistaken denial of a state-provided peremptory challenge in these circumstances; states may prescribe automatic reversal or permit harmless-error review.
Docket 07-9995
Cited authorities
- Rule 434(d)
- Fed. R. Crim. P. 24(b)
Cited by
- (HC) Wright v. McDowell
- (HC) Villarreal v. People of the State of California
- Commonwealth v. Souleymane Yacouba Issa
- United States v. Felix Gonzalez-Melendez
- State of Minnesota, Respondent v. Jason Finnegan, Petitioner, Appellant
- State of Minnesota, Respondent v. Jason Finnegan, Petitioner, Appellant
- United States v. Gonzalez-Melendez
- United States v. González-Meléndez