Bell v. Commissioner of Correction

Summary

The court affirmed the Appellate Court’s judgment granting habeas relief and ordering a new trial on the kidnapping charges. Applying the collateral-review harmless-error standard, the court concluded that the missing kidnapping instruction could have affected the verdict because the jury could have found that the restraints occurred during the robberies to incapacitate the victims rather than afterward to facilitate escape. The court therefore could not determine that the instructional error was harmless.