Rivera v. Illinois
|Rivera v. Illinois|
|Argued February 23, 2009
Decided March 31, 2009
|Full case name||Michael Rivera, Petitioner v. Illinois|
|Citations||556 U.S. ___ (more)|
|Prior history||Holding for the defendant, Supreme Court of the State of Illinois|
|Unintentional errors by the court, that would not have altered the proceedings of the case, do not warrant a new trial and do not violate the Sixth Amendment's clause of the right to a fair trial.|
|Majority||Ginsburg, joined by unanimous|
|U.S. Const. amend. VI|
The facts present a novel issue in criminal procedure. The Court will determine if a trial would have had a different outcome had all the jurors been properly seated. In the instant case, one of the jurors was, in fact, not properly seated. If the court decides this is a significant error, it must determine what legal remedy is appropriate in such a case.
The named petitioner in the case is Michael Rivera. He was convicted of two counts of first degree murder in 1998. He was then sentenced to eighty-five years in prison. During the pre-trial voir dire, Rivera's counsel used a peremptory challenge to have a juror removed from consideration. The judge deemed the challenge to be based on discriminatory factors and allowed the juror to be seated.
Appealing his subsequent guilty verdict, Rivera's attorney argued on appeal that the trial judge erred in dismissing the peremptory challenge. The Illinois Supreme Court remanded the case, giving the trial judge instructions to explain why he ruled the peremptory challenge in question to be discriminatory. The trial judge submitted gender discrimination as the relevant discriminatory factor.
Unsatisfied with this explanation, the Illinois Supreme Court held that Rivera was wrongly denied his challenge to dismiss the juror. The state supreme court found no evidence that Rivera's attorney used discriminatory considerations in arguing for the dismissal of the juror in question. Despite this, the state supreme court decided that such a mistake constituted a harmless error.
U.S. Supreme Court Ruling
James K. Leven argued the case for the petitioner. Michael A. Scodro argued the case for the respondent. Assistant to the Solicitor General Matthew D. Roberts argued the case for the United States, as amicus curiae, in support of the respondent.
The U.S. Supreme Court affirmed the Illinois Supreme Court decision in a unanimous opinion.
- "Argument Preview: Jury selection dynamics". SCOTUSblog. Retrieved 2010-07-10.[dead link]
- "Rivera v. Illinois (07-9995) | LII / Legal Information Institute". Topics.law.cornell.edu. Retrieved 2010-07-10.
- "Rivera v. Illinois, U.S. Supreme Court Case Summary & Oral Argument". Oyez.org. Retrieved 2010-07-10.
- "Rivera v. Illinois". On the Docket. Retrieved 2010-07-10.
- New York Times