Banks v. Commissioner of Correction

Summary

The court held that the Brecht harmless-error standard governs claims in state habeas proceedings alleging that the jury was not given the kidnapping instruction required by Salamon. Applying that standard, it concluded that the instructional omission was harmless because the undisputed postrobbery confinement was independently criminal and a properly instructed jury would have found the petitioner guilty beyond a reasonable doubt. The court therefore reversed the Appellate Court and directed judgment affirming the habeas court.