Justice Powell
delivered the opinion of the Court.
This case presents the question whether the harmless-error standard of Chapman v. California, 386 U. S. 18 (1967), applies to jury instructions that violate the principles of Sandstrom v. Montana, 442 U. S. 510 (1979), and Francis v. Franklin, 471 U. S. 307 (1985).
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On December 30, 1978, Charles Browning and Joy Faulk were shot to death while they sat in Browning’s pickup truck in a remote area of Rutherford County, Tennessee. Respondent Stanley Clark, Faulk’s former boyfriend, was charged with the murders.
The evidence introduced at trial showed that Browning, Faulk, and Faulk’s two young children (aged 6 and 3) had been driving in Rutherford County on the night of the murders. According to the older child, another vehicle followed Browning’s truck for about an hour. Browning pulled his truck into a private driveway, apparently to let the other ve-hide pass. The driver of the second vehide then pulled in behind Browning, thereby blocking any exit. The driver left his vehide, walked up to the cab of Browning’s truck, and fired four shots at point-blank range. One shot struck Browning in the head, two others struck Faulk in the head, and the fourth struck Faulk in the left shoulder. The killer left the scene in his vehicle. Both Browning and Faulk died.
Faulk’s children, who had not been shot, went for help, telling a local resident that “Clicker” (the nickname by which the children knew respondent) had shot Browning and their mother. Earlier that night, police had seen respondent following Browning’s truck. Police soon located respondent, but apprehended him only after a high-speed chase. Police found the murder weapon, a .25-caliber pistol that respondent had borrowed from a friend, near respondent’s home. At trial, the State relied on the foregoing evidence and on evidence showing that respondent and Joy Faulk had a stormy love affair that Faulk ended in the fall of 1978. Several times after their breakup, respondent threatened to kill Faulk if he ever found her with another man.
Respondent offered two lines of defense. First, he contended that Sam Faulk, Joy’s ex-husband, killed the victims because of a dispute concerning custody of the two Faulk children. The State rebutted this contention by introducing evidence that no such dispute existed, and that Sam Faulk was elsewhere when the murders were committed. Second, respondent argued that he was either insane or incapable of forming the requisite criminal intent. To support this argument, respondent introduced evidence that he was suffering from amnesia and could not remember the events of the night of the murders. In addition, some testimony suggested that respondent had been drinking heavily the entire day before the murders. Finally, two defense psychiatrists testified that respondent was legally insane at the time the murders were committed because his depression concerning his recent breakup with Joy Faulk made it impossible for him to conform his conduct to the law.
At the close of trial, the court instructed the jury on the elements of both first- and second-degree murder. Under Tennessee law, first-degree murder requires proof of premeditation and deliberation, while second-degree murder requires proof of malice. The court’s instructions defined malice as “an intent to do any injury to another, a design formed in the mind of doing mischief to another.” App. 186. Malice did not require proof of planning or premeditation; a killing “upon a sudden impulse of passion” sufficed if committed with intent to harm another. Id., at 187. The court then charged the jury:
“All homicides are presumed to be malicious in the absence of evidence which would rebut the implied presumption. Thus, if the State has proven beyond a reasonable . . . doubt that a killing has occurred, then it is presumed that the killing was done maliciously. But this presumption may be rebutted by either direct or circumstantial evidence, or by both, regardless of whether the same be offered by the Defendant, or exists in the evidence of the State.” Ibid.
The jury found respondent guilty of first-degree murder for killing Faulk and of second-degree murder for killing Browning.
The Tennessee Court of Criminal Appeals affirmed the convictions, rejecting respondent’s argument that the jury instructions had impermissibly shifted the burden of proof as to malice. Respondent then sought habeas corpus relief in the Middle District of Tennessee. The District Court held that the malice instruction had violated respondent’s right to have his guilt proved beyond a reasonable doubt, as that right was defined in Sandstrom v. Montana. The court went on to find that the error could not be deemed harmless because respondent had “relied upon a mens rea defense” in contesting his guilt. 611 F. Supp. 294, 302 (1983).
The Court of Appeals for the Sixth Circuit affirmed. The court agreed that the malice instruction was unconstitutional under Sandstrom. Turning to the question whether the error was harmless, the court reasoned that because respondent contested malice at his trial, an erroneous burden-shifting instruction could not be harmless under governing precedent. App. to Pet. for Cert. A-5 (citing Engle v. Koehler, 707 F. 2d 241, 246 (CA6 1983), aff’d by an equally divided Court, 466 U. S. 1 (1984)). The court reached this conclusion “despite the substantial evidence of petitioner’s guilt,” and added:
“Were we writing on a clean slate, we would direct our inquiry to that suggested by Justice Powell (dissenting) in Connecticut v. Johnson, 460 U. S. at 97 n. 5:
“ ‘the inquiry is whether the evidence is so dispositive of intent that a reviewing court can say beyond a reasonable doubt that the jury would have found it unnecessary to rely on the presumption.’
“If that were the question in this case ... we might be able to respond in the affirmative.” App. to Pet. for Cert. A-6.
The court nevertheless affirmed the order granting habeas corpus relief. We granted certiorari limited to the question whether the Court of Appeals’ harmless-error analysis was correct. 474 U. S. 816 (1985).
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A
In Chapman v. California, 386 U. S. 18 (1967), this Court rejected the argument that errors of constitutional dimension necessarily require reversal of criminal convictions. And since Chapman, “we have repeatedly reaffirmed the principle that an otherwise valid conviction should not be set aside if the reviewing court may confidently say, on the whole record, that the constitutional error was harmless beyond a reasonable doubt.” Delaware v. Van Arsdall, 475 U. S. 673, 681 (1986). That principle has been applied to a wide variety of constitutional errors. E. g., id., at 684 (failure to permit cross-examination concerning witness bias); Rushen v. Spain, 464 U. S. 114, 118 (1983) (per curiam) (denial of right to be present at trial); United States v. Hasting, 461 U. S. 499, 508-509 (1983) (improper comment on defendant’s failure to testify); Moore v. Illinois, 434 U. S. 220, 232 (1977) (admission of witness identification obtained in violation of right to counsel); Milton v. Wainwright, 407 U. S. 371 (1972) (admission of confession obtained in violation of right to counsel); Chambers v. Maroney, 399 U. S. 42, 52-53 (1970) (admission of evidence obtained in violation of the Fourth Amendment). See also Hopper v. Evans, 456 U. S. 605, 613-614 (1982) (citing Chapman and finding no prejudice from trial court’s failure to give lesser included offense instruction). Our application of harmless-error analysis in these cases has not reflected a denigration of the constitutional rights involved. Instead, as we emphasized earlier this Term:
“The harmless-error doctrine recognizes the principle that the central purpose of a criminal trial is to decide the factual question of the defendant’s guilt or innocence, United States v. Nobles, 422 U. S. 225, 230 (1975), and promotes public respect for the criminal process by focusing on the underlying fairness of the trial rather than on the virtually inevitable presence of immaterial error. Cf. R. Traynor, The Riddle of Harmless Error 50 (1970) (‘Reversal for error, regardless of its effect on the judgment, encourages litigants to abuse the judicial process and bestirs the public to ridicule it’).” Delaware v. Van Arsdall, supra, at 681.
Despite the strong interests that support the harmless-error doctrine, the Court in Chapman recognized that some constitutional errors require reversal without regard to the evidence in the particular case. 386 U. S., at 23, n. 8, citing Payne v. Arkansas, 356 U. S. 560 (1958) (introduction of coerced confession); Gideon v. Wainwright, 372 U. S. 335 (1963) (complete denial of right to counsel); Tumey v. Ohio, 273 U. S. 510 (1927) (adjudication by biased judge). This limitation recognizes that some errors necessarily render a trial fundamentally unfair. The State of course must provide a trial before an impartial judge, Turney v. Ohio, supra, with counsel to help the accused defend against the State’s charge, Gideon v. Wainwright, supra. Compare Holloway v. Arkansas, 435 U. S. 475, 488-490 (1978), with Cuyler v. Sullivan, 446 U. S. 335, 348-350 (1980). Without these basic protections, a criminal trial cannot reliably serve its function as a vehicle for determination of guilt or innocence, see Powell v. Alabama, 287 U. S. 45 (1932), and no criminal punishment may be regarded as fundamentally fair. Harmless-error analysis thus presupposes a trial, at which the defendant, represented by counsel, may present evidence and argument before an impartial judge and jury. See Delaware v. Van Arsdall, supra, at 681 (constitutional errors may be harmless “in terms of their effect on the factfinding process at trial”) (emphasis added); Chapman, supra, at 24 (error is harmless if, beyond a reasonable doubt, it “did not contribute to the verdict obtained”) (emphasis added).
Similarly, harmless-error analysis presumably would not apply if a court directed a verdict for the prosecution in a criminal trial by jury. We have stated that “a trial judge is prohibited from entering a judgment of conviction or directing the jury to come forward with such a verdict. . . regardless of how overwhelmingly the evidence may point in that direction.” United States v. Martin Linen Supply Co., 430 U. S. 564, 572-573 (1977) (citations omitted). Accord, Carpenters v. United States, 330 U. S. 395, 408 (1947). This rule stems from the Sixth Amendment’s clear command to afford jury trials in serious criminal cases. See Duncan v. Louisiana, 391 U. S. 145 (1968). Where that right is altogether denied, the State cannot contend that the deprivation was harmless because the evidence established the defendant’s guilt; the error in such a case is that the wrong entity judged the defendant guilty.
We have emphasized, however, that while there are some errors to which Chapman does not apply, they are the exception and not the rule. United States v. Hasting, supra, at 509. Accordingly, if the defendant had counsel and was tried by an impartial adjudicator, there is a strong presumption that any other errors that may have occurred are subject to harmless-error analysis. The thrust of the many constitutional rules governing the conduct of criminal trials is to ensure that those trials lead to fair and correct judgments. Where a reviewing court can find that the record developed at trial establishes guilt beyond a reasonable doubt, the interest in fairness has been satisfied and the judgment should be affirmed. As we have repeatedly stated, “the Constitution entitles a criminal defendant to a fair trial, not a perfect one.” Delaware v. Van Arsdall, 475 U. S., at 681; United States v. Hasting, 461 U. S., at 508-509.
B
Applying these principles to this case is not difficult. Respondent received a full opportunity to put on evidence and make argument to support his claim of innocence. He was tried by a fairly selected, impartial jury, supervised by an impartial judge. Apart from the challenged malice instruction, the jury in this case was clearly instructed that it had to find respondent guilty beyond a reasonable doubt as to every element of both first- and second-degree murder. See also n. 2, supra. Placed in context, the erroneous malice instruction does not compare with the kinds of errors that automatically require reversal of an otherwise valid conviction. We therefore find that the error at issue here — an instruction that impermissibly shifted the burden of proof on malice — is not “so basic to a fair trial” that it can never be harmless. Cf. Chapman, 386 U. S., at 23.
The purpose behind the rule of Sandstrom v. Montana supports this conclusion. Sandstrom was a logical extension of the Court’s holding in In re Winship, 397 U. S. 358 (1970), that the prosecution must prove “every fact necessary to constitute the crime with which [the defendant] is charged” beyond a reasonable doubt. Id., at 364; see Sandstrom, 442 U. S., at 520, 523; Francis v. Franklin, 471 U. S., at 313. The purpose of that rule is to ensure that only the guilty are criminally punished. As the Court stated last Term in Francis v. Franklin, the rule “protects the ‘fundamental value determination of our society,’ given voice in Justice Harlan’s concurrence in Winship, that ‘it is far worse to convict an innocent man than to let a guilty man go free.’ ” Ibid., quoting Winship, supra, at 372 (Harlan, J., concurring). When the verdict of guilty reached in a case in which Sandstrom error was committed is correct beyond a reasonable doubt, reversal of the conviction does nothing to promote the interest that the rule serves.
Nor is Sandstrom error equivalent to a directed verdict for the State. When a jury is instructed to presume malice from predicate facts, it still must find the existence of those facts beyond a reasonable doubt. Connecticut v. Johnson, 460 U. S. 73, 96-97 (1983) (Powell, J., dissenting). In many cases, the predicate facts conclusively establish intent, so that no rational jury could find that the defendant committed the relevant criminal act but did not intend to cause injury. See, e. g., Lamb v. Jernigan, 683 F. 2d 1332, 1342-1343 (CA11 1982), cert. denied, 460 U. S. 1024 (1983). In that event the erroneous instruction is simply superfluous: the jury has found, in Winship’s words, “every fact necessary” to establish every element of the offense beyond a reasonable doubt. See Connecticut v. Johnson, supra, at 97 (Powell, J., dissenting); Jeffries & Stephan, Defenses, Presumptions, and Burden of Proof in the Criminal Law, 88 Yale L. J. 1325, 1388, n. 192 (1979).
No one doubts that the trial court properly could have instructed the jury that it could infer malice from respondent’s conduct. See Francis v. Franklin, supra, at 314-315; Ulster County Court v. Allen, 442 U. S. 140, 157-163 (1979). Indeed, in the many cases where there is no direct evidence of intent, that is exactly how intent is established. For purposes of deciding this case, it is enough to recognize that in some cases that inference is overpowering. See Hopper v. Evans, 456 U. S., at 613. It would further neither justice nor the purposes of the Sandstrom rule to reverse a conviction in such a case. We accordingly hold that Chapman’s harmless-error standard applies in cases such as this one.
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Although the Court of Appeals acknowledged that Sand-strom error might in some cases be harmless, its analysis of the issue cannot square with Chapman. The court concluded that a Sandstrom error could never be harmless where a defendant contests intent. App. to Pet. for Cert. A-5. But our harmless-error cases do not turn on whether the defendant conceded the factual issue on which the error bore. Rather, we have held that “Chapman mandates consideration of the entire record prior to reversing a conviction for constitutional errors that may be harmless.” United States v. Hasting, 461 U. S., at 509, n. 7. The question is whether, “on the whole record . . . the error . . . [is] harmless beyond a reasonable doubt.” Id., at 510. See also Chapman, 386 U. S., at 24 (“[BJefore a federal constitutional error can be held harmless, the court must be able to declare a belief that it was harmless beyond a reasonable doubt”); Connecticut v. Johnson, 460 U. S., at 97, n. 5 (Powell, J., dissenting) (in cases of Sandstrom error, “the inquiry is whether the evidence was so dispositive of intent that a reviewing court can say beyond a reasonable doubt that the jury would have found it unnecessary to rely on the presumption”). Thus, the fact that respondent denied that he had “an intent to do any injury to another,” App. 186, does not dispose of the harmless-error question.
Although we “plainly have the authority” to decide whether, on the facts of a particular case, a constitutional error was harmless under the Chapman standard, we “do so sparingly.” United States v. Hasting, supra, at 510. The Court of Appeals has not yet applied Chapman to the facts of this case. We therefore remand to that court for determination of whether the error committed in this case was harmless beyond a reasonable doubt.
IV
The judgment of the Court of Appeals is vacated, and the case is remanded for further proceedings consistent with this opinion.
It is so ordered.
In Connecticut v. Johnson, 460 U. S. 73 (1983), the Court was equally divided on the question whether ordinary harmless-error analysis was appropriate in cases of Sandstrom error. Compare 460 U. S., at 84-87 (plurality opinion) (such error “is the functional equivalent of a directed verdict” on intent, and is therefore harmless only when the defendant concedes intent), with id., at 95-99 (Powell, J., dissenting) (Chapman standard applies to Sandstrom error). Cf. 460 U. S., at 88 (Stevens, J., concurring in judgment) (joining affirmance of state-court decision that Sandstrom error could not be harmless, but on the ground that the decision was actually one of state law). The Johnson plurality noted that state and federal courts were in conflict on this issue. 460 U. S., at 75, n. 1 (collecting cases). Due in part to the divided views in Johnson, that conflict has persisted. Compare, e. g., Tucker v. Kemp, 762 F. 2d 1496, 1501-1503 (CA11 1985) (en banc) (applying Chapman harmless-error analysis), cert. denied, post, p. 1022, with In re Hamilton, 721F. 2d 1189, 1190-1191 (CA9 1983) (holding that Sandstrom error would be harmless only if intent was not contested at trial).
The Court of Criminal Appeals noted that, almost immediately following the “presumption” instruction, the judge charged:
“The question of whether the alleged killing was done with malice is for you to determine from the entire case, and you should look to all of the facts and circumstances developed by the evidence to determine whether the State has . . . proven beyond a reasonable doubt the existence of malice. If you have a reasonable doubt as to whether the alleged killing was done with malice, then the Defendant cannot be guilty of murder in the second degree and you must acquit him of that offense.” App. 188.
The Court of Criminal Appeals reasoned that this instruction adequately informed the jurors that the burden of proof on malice remained on the State at all times. App. to Pet. for Cert. A-37 to A-39.
In Sandstrom we held that an instruction creating a presumption of malice that has the effect of shifting the burden of proof on intent to the defendant violates due process under the rule of In re Winship, 397 U. S. 358 (1970). Sandstrom v. Montana, 442 U. S., at 523-524. Sandstrom was decided shortly before respondent’s trial commenced. 611 F. Supp. 294, 296, n. 3 (1983).
The Court of Appeals’ judgment is reported at 762 F. 2d 1006 (1985). The court’s opinion is unpublished.
We thus do not consider whether, taken in context, the instructions were permissible under our decisions in Sandstrom and in Francis v. Franklin, 471 U. S. 307 (1985). For purposes of our harmless-error analysis, we assume that the Court of Appeals properly held that the instructions were unconstitutional.
Each of the examples Chapman cited of errors that could never be harmless either aborted the basic trial process, Payne v. Arkansas, 356 U. S. 560 (1958) (use of coerced confession), or denied it altogether, Gideon v. Wainwright, 372 U. S. 335 (1963) (denial of counsel); Tumey v. Ohio, 273 U. S. 510 (1927) (biased adjudicator).
Unlike errors such as judicial bias or denial of counsel, the error in this case did not affect the composition of the record. Evaluation of whether the error prejudiced respondent thus does not require any difficult inquiries concerning matters that might have been, but were not, placed in evidence. Cf. Holloway v. Arkansas, 435 U. S. 475, 490-491 (1978). Consequently, there is no inherent difficulty in evaluating whether the error prejudiced respondent in this case. See United States v. Frady, 456 U. S. 152, 171-174 (1982) (evaluating Sandstrom error for prejudice under the “cause and actual prejudice” standard of Wainwright v. Sykes, 433 U. S. 72 (1977)).
“Because a presumption does not remove the issue of intent from the jury’s consideration, it is distinguishable from other instructional errors that prevent a jury from considering an issue.” Connecticut v. Johnson, 460 U. S., at 95, n. 3 (Powell, J., dissenting). Cf. Jackson v. Virginia, 443 U. S. 307, 320, n. 14 (1979) (suggesting that failure to instruct a jury as to the reasonable-doubt standard cannot be harmless).
See Brooks v. Kemp, 762 F. 2d 1383, 1423 (CA11 1985) (Kravitch, J., concurring and dissenting) (emphasizing that juries are free to infer intent from conduct).
In Hopper v. Evans, we held that States are not constitutionally required to instruct juries about lesser included offenses where such instructions are not warranted by the evidence. The defendant in that case claimed that the trial court should have instructed the jury as to unintentional homicide during the commission of a robbery. We concluded:
“It would be an extraordinary perversion of the law to say that intent to kill is not established when a felon, engaged in an armed robbery, admits to shooting his victim in the back .... The evidence not only supported the claim that respondent intended to kill the victim, but affirmatively negated any claim that he did not intend to kill the victim. An instruction on the offense of unintentional killing during this robbery was therefore not warranted.” 456 U. S., at 613 (citation omitted).
As Hopper suggests, it would defy common sense to conclude that an execution-style killing or a violent torture-murder was committed unintentionally. See Connecticut v. Johnson, 460 U. S., at 99, n. 7 (Powell, J., dissenting). It follows that no rational jury would need to rely on an erroneous presumption instruction to find malice in such cases. Id., at 97, and n. 5.
We think the dissent, and not the Court, “asks and answers the wrong question” in this case. Post, at 596 (opinion of Blackmun, J.). We agree that the determination of guilt or innocence, according to the standard of proof required by Winship and its progeny, is for the jury rather than the court. See post, at 593. Harmless-error analysis addresses a different question: what is to be done about a trial error that, in theory, may have altered the basis on which the jury decided the case, but in practice clearly had no effect on the outcome? This question applies not merely to Sandstrom violations, but to other errors that may have affected either the instructions the jury heard or the record it considered — including errors such as mistaken admission of evidence, or unconstitutional comment on a defendant’s silence, or erroneous limitation of a defendant’s cross-examination of a prosecution witness. All of these errors alter the terms under which the jury considered the defendant’s guilt or innocence, and therefore all theoretically impair the defendant’s interest in having a jury decide his case. The dissent’s argument — that the Sixth Amendment forbids a reviewing court to decide the impact of a trial error on the outcome, post, at 593-594 — logically implies that all such errors are immune from harmless-error analysis. Yet this Court repeatedly has held to the contrary. E. g., Delaware v. Van Arsdall, 475 U. S. 673 (1986) (limitation on defendant’s cross-examination); United States v. Hasting, 461 U. S. 499 (1983) (improper comment on defendant’s failure to testify); Moore v. Illinois, 434 U. S. 220 (1977) (admission of improperly obtained witness identification). Indeed, Chapman v. California, 386 U. S. 18 (1967), the beginning of this line of cases, applied harmless-error analysis to an error that placed an improper argument before the jury. Id., at 24-25 (finding comment on defendant’s silence harmful). See also Hopper v. Evans, 456 U. S., at 613-614 (citing Chapman, and finding error in jury instructions harmless). These decisions, ignored by the dissent, strongly support application of harmless-error analysis in the context of Sandstrom error.
The dissent contends that the jury’s decision to convict respondent of only one count of premeditated murder “aptly illustrate^] why harmless-error analysis is inappropriate” in cases where intent is at issue. Post, at 594 (opinion of Blackmun, J.). This argument is without merit. The jury determined that respondent was guilty beyond a reasonable doubt of “intend[ing] to take the life” of Joy Faulk “with cool purpose.” App. 185 (trial court’s charge defining premeditation). The jury then determined that respondent was guilty of the malicious, but not premeditated, murder of Charles Browning. The only alleged error in these instructions was the trial court’s instruction that the jury could presume malice from a killing. Respondent’s (and the dissent’s) theory is that a proper instruction on the burden of proof on malice might have led the jury to find neither malice nor premeditation as to Faulk’s killing. This argument is implausible on its face.
We leave the question whether the error in this case was harmless beyond a reasonable doubt to the Court of Appeals on remand. We do suggest that the different verdicts for the two killings in no way support respondent’s contention that the Sandstrom error in this case was prejudicial.
The parties disagree as to the scope of the relevant evidence that must be assessed under Chapman. In particular, petitioner argues that evidence of amnesia, of respondent’s drunkenness on the day of the murders, and of insanity is irrelevant to malice. Respondent disagrees. These are, of course, issues of Tennessee law in the first instance, and we need not resolve them here. Nor do we express any view as to whether, assuming all the evidence in question is relevant to malice, the error in this case was nevertheless harmless beyond a reasonable doubt.
What follows is an opinion from the Supreme Court of the United States. Your task is to determine whether the decision of the court whose decision the Supreme Court reviewed was itself liberal or conservative. In the context of issues pertaining to criminal procedure, civil rights, First Amendment, due process, privacy, and attorneys, consider liberal to be pro-person accused or convicted of crime, or denied a jury trial, pro-civil liberties or civil rights claimant, especially those exercising less protected civil rights (e.g., homosexuality), pro-child or juvenile, pro-indigent pro-Indian, pro-affirmative action, pro-neutrality in establishment clause cases, pro-female in abortion, pro-underdog, anti-slavery, incorporation of foreign territories anti-government in the context of due process, except for takings clause cases where a pro-government, anti-owner vote is considered liberal except in criminal forfeiture cases or those where the taking is pro-business violation of due process by exercising jurisdiction over nonresident, pro-attorney or governmental official in non-liability cases, pro-accountability and/or anti-corruption in campaign spending pro-privacy vis-a-vis the 1st Amendment where the privacy invaded is that of mental incompetents, pro-disclosure in Freedom of Information Act issues except for employment and student records. In the context of issues pertaining to unions and economic activity, consider liberal to be pro-union except in union antitrust where liberal = pro-competition, pro-government, anti-business anti-employer, pro-competition, pro-injured person, pro-indigent, pro-small business vis-a-vis large business pro-state/anti-business in state tax cases, pro-debtor, pro-bankrupt, pro-Indian, pro-environmental protection, pro-economic underdog pro-consumer, pro-accountability in governmental corruption, pro-original grantee, purchaser, or occupant in state and territorial land claims anti-union member or employee vis-a-vis union, anti-union in union antitrust, anti-union in union or closed shop, pro-trial in arbitration. In the context of issues pertaining to judicial power, consider liberal to be pro-exercise of judicial power, pro-judicial "activism", pro-judicial review of administrative action. In the context of issues pertaining to federalism, consider liberal to be pro-federal power, pro-executive power in executive/congressional disputes, anti-state. In the context of issues pertaining to federal taxation, consider liberal to be pro-United States and conservative pro-taxpayer. In miscellaneous, consider conservative the incorporation of foreign territories and executive authority vis-a-vis congress or the states or judcial authority vis-a-vis state or federal legislative authority, and consider liberal legislative veto. The lower court's decision direction is unspecifiable if the manner in which the Supreme Court took jurisdiction is original or certification; or if the direction of the Supreme Court's decision is unspecifiable and the main issue pertains to private law or interstate relations