Belton v. State
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The Supreme Court affirmed in part and reversed in part the judgment of the appellate court deciding the merits of Defendant's appeal and affirming Defendant's conviction for voluntary manslaughter and related offenses, holding that the constitutional right to a fair trial extends to appellate proceedings, that the appellate court erred in deciding the merits of Defendant's appeal, and that a new trial was required.
During Defendant's appeal, the appellate court compared Defendant, an African American man, to the mythical monster Grendel in Beowulf. On appeal to the Supreme Court Defendant argued that this reference evoked racist tropes of African Americans and that other passages in the appellate court's dicta deprived him of his constitutional right to a fair and impartial appellate process. The Supreme Court remanded the case for a new trial, holding (1) the right to fair and impartial judges extends to appellate proceedings; and (2) the appellate court erred in concluded that the exclusion of certain evidence was harmless because its exclusion was harmful, reversible error.
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