State of West Virginia v. Jim Boyd

Summary

The court reversed the first-degree murder conviction and remanded for a new trial because the defendant was improperly impeached with his custodial silence, the prosecutor engaged in cumulatively prejudicial misconduct, and the defendant was absent during a critical trial-stage hearing. It held that the State may use voluntary, inconsistent pretrial statements for impeachment, but may not compel a defendant to explain or justify silence after invoking the privilege. The court also clarified that the State bears the burden of proving beyond a reasonable doubt that a constitutional violation was harmless.