Karen v. California

Background

The case involves a man who acted as his own lawyer and told the judge he had been jailed five years and had no civilian clothes. He asked the court to provide civilian clothing but was required to wear clothes labeled "L. A. CO. JAIL" at his manslaughter trial. The California Court of Appeal thought the trial court erred but called the error harmless and left the conviction standing.

Reasoning

The core question is whether forcing a defendant to wear identifiable jail clothes unfairly undermines the presumption of innocence. Justice Marshall, in a dissent joined by Justice Brennan and relying on a recent decision (Estelle v. Williams) argued that such clothing can bias jurors and that poverty cannot waive the presumption of innocence. The appellate court considered a separate California practice—trying a manslaughter defendant on a murder charge, allowing murder evidence, and instructing on murder degrees—and said that practice already taints jurors so the clothing error was harmless.

Real world impact

Because the Supreme Court denied review, the lower-court judgment of involuntary manslaughter remains in place in this case. The denial leaves intact the California procedure and the appellate ruling that found the clothing error harmless. This is not a decision on the full merits by the high court, so the legal question could be revisited in a later, different case.

Dissents or concurrances

Justice Marshall would have granted review and criticized the harmless-error reasoning, warning that treating two alleged errors as cancelling each other out undermines equal justice for poor defendants.