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Glebe v. Frost, 14-95

In this case, the trial court restricted the defense's closing arguments, which defendant asserts constituted structural error requiring automatic reversal. Judgment of the Ninth Circuit reversing defendant's conviction on various robbery, burglary, and assault counts, and instructing the District Court to grant habeas relief, is reversed and remanded, where: 1) even assuming, for argument's sake, that the trial court violated the Constitution in restricting the defense's closing arguments, it was not clearly established that its mistake ranked as structural error; and 2) the restriction, which precluded the defense from simultaneously contesting reasonable doubt and claiming duress, does not suggest structural error due to supposed extraction of a tacit admission to elements of the crimes, given that the introduction of a coerced confession is classified only as a trial error.

Appellate Information

  • Decided 11/17/2014
  • Published 12/04/2014



  • United States Supreme Court