Donnelly v. DeChristoforo
Headline: Prosecutor’s closing remarks implying the defendant sought a lesser plea did not violate due process, the Court reversed the appeals court and left the murder conviction and life sentence in place.
Holding:
- Leaves the murder conviction and life sentence intact.
- Limits federal habeas relief for isolated improper prosecutor remarks.
- Shows trial judges' curative instructions can cure some improper remarks.
Summary
Background
A defendant was tried for first-degree murder in Massachusetts, convicted, and sentenced to life after the jury recommended against the death penalty. At the close of the evidence, one codefendant pleaded guilty to second-degree murder and the judge told the jury. During closing argument the prosecutor made two challenged remarks: one expressing a personal belief in the defendant's guilt and another suggesting the defense wanted the jury to find the defendant guilty of a lesser offense. Defense counsel objected. The judge later told the jury that closing arguments are not evidence, singled out the prosecutor's statement as unsupported, and instructed the jury to disregard it. State courts and a federal district court denied relief, but the Court of Appeals granted habeas relief by a divided vote.
Reasoning
The Supreme Court framed the issue narrowly as a Fourteenth Amendment due process claim and asked whether the prosecutor's remarks so infected the trial with unfairness that the conviction must be set aside. The Court explained that isolated, ambiguous comments in argument differ from the intentional use of false evidence or the withholding of key testimony. It emphasized that closing argument is not evidence, that the trial judge promptly and specifically admonished the jury, and that, viewed in the context of the whole trial, the comments did not amount to a denial of constitutional due process. The Court therefore reversed the Court of Appeals.
Real world impact
This ruling leaves the conviction and sentence intact and makes clear that not every improper prosecutorial remark requires federal habeas relief. It affirms that trial judges' curative instructions can cure some errors, while also stating that blatant or deliberate misrepresentation remains unconstitutional.
Dissents or concurrances
One Justice would have dismissed certiorari; another dissented, arguing the prosecutor's insinuation was prejudicial and the instruction insufficient, and two Justices joined that dissent on its key points.
Opinions in this case:
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