Weaver v. Massachusetts

Nathaniel Weaver was convicted in 1999 for the murder of 15-year-old Christine Ricketts. During jury selection, the courtroom was closed to the public due to space limitations, and his defense attorney did not object. The Massachusetts Supreme Judicial Court overturned the conviction because the closure violated Weaver's Sixth Amendment right to a public trial. In a 2004 retrial, Weaver was again convicted. He later filed a motion claiming his original lawyer provided ineffective assistance by failing to object to the closure, arguing that but for this error, he would not have faced the second trial where new damaging evidence was introduced. The state courts denied relief, holding that Weaver failed to demonstrate prejudice under the Strickland standard. The U.S. Supreme Court agreed to hear the case to resolve the interplay between structural error and the prejudice requirement for ineffective assistance claims.

The Supreme Court affirmed the lower court in a 6-3 decision. Justice Kennedy, writing for the majority, held that while a courtroom closure during jury selection is a structural error, a defendant raising an ineffective assistance of counsel claim based on counsel's failure to object must independently demonstrate prejudice under Strickland. Because Weaver could not show a reasonable probability that he would have been acquitted in the first trial had the objection been made, and the remedy for the public trial violation—a new trial—was already provided, his claim failed.

Whether the prejudice prong of the Strickland test for ineffective assistance of counsel is automatically satisfied when counsel fails to object to a courtroom closure that constitutes a structural error, or whether the defendant must still show a reasonable probability that the outcome of the proceeding would have been different absent the deficient performance.

The ruling clarified that not all constitutional violations automatically satisfy the prejudice analysis in ineffective assistance of counsel claims, even when they involve fundamental structural protections like the public trial right. It emphasized that defendants must establish a direct causal link between attorney error and trial outcome, reinforcing the high bar set by Strickland. The decision curtailed a potential avenue for post-conviction relief based on public trial closures, underscoring the importance of contemporaneous objections and the distinct nature of remedies for structural errors versus claims of deficient lawyering.