Williams v. Swarthout, No. 11-57255 (9th Cir. 2014)
Annotate this CasePetitioner, convicted of one count of false imprisonment and one count of forcible sexual penetration by a foreign object, appealed the denial of federal habeas relief on the basis that the state trial court's misstatement that he had pled guilty violated his constitutional rights. The court concluded that the trial court's misstatement deprived petitioner of his Sixth Amendment right to an impartial jury and his Fifth and Fourteenth Amendment due process rights to the presumption of innocence. Viewed in the context of the trial as a whole, the initial misstatement and the trial court's ineffective attempts to cure it were devastating to petitioner. Accordingly, the constitutional error was manifest and not harmless. The court reversed the denial of the petition for writ of habeas corpus and remanded with instructions to grant the writ.
Court Description: Habeas Corpus. Reversing the district court’s denial of Bryant Keith Williams’s habeas corpus petition and remanding, the panel held that the state trial court’s misstatement that Williams had pled guilty – a misstatement made immediately before trial commenced and not corrected until the jury began deliberating – violated his due process rights by depriving him of the presumption of innocence, and violated his Sixth Amendment right to an impartial jury. The panel concluded that the California Court of Appeal decided both Williams’s state and federal claims the same way: it found error under both state and federal constitutional law, but concluded that both were harmless. The panel held that the constitutional error was not rendered harmless by flawed curative instructions. Dissenting, Judge Murguia disagreed with the majority’s conclusion that the California Court of Appeal found state and federal constitutional error. She would hold that the California Court of Appeal determined that Williams’s state and federal constitutional rights were not violated, and that this was not an unreasonable application of clearly established federal law.
The court issued a subsequent related opinion or order on August 18, 2015.
The court issued a subsequent related opinion or order on August 18, 2015.
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