Yates v. Evatt

Background

A man (Dale Yates) and an accomplice (Henry Davis) robbed a country store. Yates shot and wounded the store owner and fled; Davis stabbed and killed the owner’s mother during a struggle and was then killed. Yates was tried as an accomplice to murder. At trial, the judge told jurors they could presume a killer’s "malice" (intent to kill) from committing an unlawful act or from using a deadly weapon. The South Carolina Supreme Court later found those instructions unconstitutional but ruled they were harmless and left the conviction in place.

Reasoning

The Court examined whether those burden-shifting instructions could be treated as harmless error. It explained that a reviewing court must identify what evidence the jury actually considered and then decide whether that evidence, independent of the unconstitutional presumptions, proved the presumed fact beyond a reasonable doubt. The Court found the state court used a deficient standard and misread the record. Important facts were unclear — the only autopsy showed a single chest wound and the eyewitness account did not support a multiple stabbing — so the Court could not say beyond a reasonable doubt that the jury did not rely on the improper presumptions. The Supreme Court therefore reversed.

Real world impact

The decision requires state courts to use the correct harmless-error test when juries are told to presume intent from certain facts. It limits the ability of prosecutors to rely on instructions that shift the burden of proof and protects defendants when jury instructions could have caused the jury to apply the wrong burden of proof. The case was sent back for further proceedings consistent with this opinion.

Dissents or concurrances

Justice Scalia concurred in the judgment but disagreed about applying the record: he thought the deadly-weapon presumption was harmless here but agreed the unlawful-act presumption was not harmless, emphasizing concerns about the jury using the wrong burden of proof.