Rivera v. Illinois
Encyclopedia
Rivera v. Illinois was a case decided by the United States Supreme Court
in 2009. Oral arguments took place Monday, February 23, 2009.
. 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.
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
.
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.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
in 2009. Oral arguments took place Monday, February 23, 2009.
Issue
The facts present a novel issue in criminal procedureCriminal procedure
Criminal procedure refers to the legal process for adjudicating claims that someone has violated criminal law.-Basic rights:Currently, in many countries with a democratic system and the rule of law, criminal procedure puts the burden of proof on the prosecution – that is, it is up to the...
. 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
Legal remedy
A legal remedy is the means with which a court of law, usually in the exercise of civil law jurisdiction, enforces a right, imposes a penalty, or makes some other court order to impose its will....
is appropriate in such a case.
Facts
The named petitionerPetitioner
A petitioner is a person who pleads with governmental institution for a legal remedy or a redress of grievances, through use of a petition.-In the courts:The petitioner may seek a legal remedy if the state or another private person has acted unlawfully...
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
Voir dire
Voir dire is a phrase in law which comes from the Anglo-Norman language. In origin it refers to an oath to tell the truth , i.e., to say what is true, what is objectively accurate or subjectively honest, or both....
, Rivera's counsel used a peremptory challenge
Peremptory challenge
Peremptory challenge usually refers to a right in jury selection for the defense and prosecution to reject a certain number of potential jurors who appear to have an unfavorable bias without having to give any reason...
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
Harmless error
A harmless error is a ruling by a trial judge that, although mistaken, does not meet the burden for a losing party to reverse the original decision of the trier of fact on appeal, or to warrant a new trial. Harmless error is easiest to understand in an evidentiary context...
.
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. RobertsMatthew D. Roberts
Matthew D. Roberts is an American lawyer who is an Assistant to the Solicitor General of the United States.-Schooling:He graduated from Harvard College magna cum laude in 1984 and graduated first in his class from Harvard Law School in 1989.-Career:...
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.