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Carter v. Kentucky, 450 U.S. 288, 101 S.Ct. 1112, 67 L.Ed.2d 241

Facts

Lonnie Joe Carter was arrested following a police chase after two men fled from an alley near a hardware store. During the chase, Carter dropped items that were later linked to the burglary of the store. At trial, Carter chose not to testify, and his defense counsel requested a jury instruction stating that the jury should not infer guilt from his silence. The trial judge denied this request, leading to Carter's conviction for burglary and being a persistent felony offender.

In the early morning of December 22, 1978, Officer Deborah Ellison of the Hopkinsville, Kentucky, Police Department, on routine patrol in downtown Hopkinsville, noticed something in the alley between Young's Hardware Store and Edna's Furniture Store. She backed her car up, flashed her spotlight down the alley, and saw two men stooped alongside one of the buildings. The men ran off.

Issue

Did the trial judge's refusal to give a jury instruction that a defendant's silence cannot be used as an inference of guilt violate the defendant's rights under the Fifth and Fourteenth Amendments?

The constitutional question presented by this case is one the Court has specifically anticipated and reserved, first in Griffin v. California, 380 U.S. 609, 615, n. 6, 85 S.Ct. 1229, 1233, n. 6, 14 L.Ed.2d 106, and more recently in Lakeside v. Oregon, 435 U.S. 333, 337, 98 S.Ct. 1091, 1093, 55 L.Ed.2d 319.

Rule

A state trial judge has a constitutional obligation to provide a 'no adverse inference' instruction upon a defendant's request, as this instruction is necessary to protect the defendant's Fifth Amendment right against self-incrimination.

The principles enunciated in our cases construing this privilege, against both statutory and constitutional backdrops, lead unmistakably to the conclusion that the Fifth Amendment requires that a criminal trial judge must give a 'no-adverse-inference' jury instruction when requested by a defendant to do so.

Analysis

The Supreme Court analyzed the implications of a defendant's silence during a trial and the potential for jurors to draw adverse inferences from that silence. The Court emphasized that without a specific instruction, jurors might speculate about the reasons for a defendant's silence, which could unfairly prejudice the defendant. The Court concluded that the trial judge's refusal to provide the requested instruction constituted a violation of the defendant's constitutional rights.

The Court observed in Lakeside that the petitioner's argument there rested on 'two very doubtful assumptions:' First, that the jurors have not noticed that the defendant did not testify and will not, therefore, draw adverse inferences on their own. Second, that the jurors will totally disregard the instruction, and affirmatively give weight to what they have been told not to consider at all.

Conclusion

The Supreme Court reversed the judgment of the Kentucky Supreme Court, holding that the trial judge's failure to provide the requested jury instruction was unconstitutional. The case was remanded for further proceedings consistent with this opinion.

For the reasons stated, the judgment is reversed, and the case is remanded to the Supreme Court of Kentucky for further proceedings not inconsistent with this opinion.

Who won?

Carter prevailed in the Supreme Court, as the Court recognized his constitutional right to a jury instruction regarding his silence, which the trial judge had denied.

Carter was entitled to the jury instruction that he requested.

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