reasonable possibility error in Pennsylvania

2026Whenever there is a reasonable possibility that an error might have contributed to the conviction, the error is not harmless.” Id. at 164 (citation and internal quotation marks omitted).

2025Whenever there is a reasonable possibility that an error might have contributed to the conviction, the error is not harmless.” Id. at 164 (citation and original quotation marks omitted).

2019In other words, an error cannot be harmless if there is a reasonable possibility the error might have contributed to the conviction.” Cooley, 118 A.3d at 380 (citation omitted); see also Commonwealth v. Mitchell, 576 Pa. 258 , 839 A.2d 202 , 214– 15 (2003) (“An error will be deemed harmless where the appellate court concludes beyond a reasonable doubt that the error could not have contributed to the verdict.”). - 11 - J-A22002-19 Harmless error exists where: (1) the error did not prejudice the defendant or the prejudice was de minimis; (2) the erroneously admitted evidence was merely cumulativ

2019In other words, an error cannot be harmless if there is a reasonable possibility the error might have contributed to the conviction.” Cooley, 118 A.3d at 380 (citation omitted); see also Commonwealth v. Mitchell, 576 Pa. 258 , 839 A.2d 202 , 214– 15 (2003) (“An error will be deemed harmless where the appellate court concludes beyond a reasonable doubt that the error could not have contributed to the verdict.”). - 11 - J-A22002-19 Harmless error exists where: (1) the error did not prejudice the defendant or the prejudice was de minimis; (2) the erroneously admitted evidence was merely cumulativ

2026“An error is harmless if it could not have contributed to the verdict, or stated conversely, an error cannot be harmless if there is a reasonable possibility the error might have contributed to the conviction.” Commonwealth v. Poplawski, 130 A.3d 697, 716 (Pa. 2015).

2025See Commonwealth v. Hamlett, 234 A.3d 486 , 492 (Pa. 2020) (“sua sponte invocation of the harmless error doctrine is not inappropriate as it does nothing more than affirm a valid judgment of sentence on an alternative basis”) (citation omitted); Commonwealth v. Frein, 206 A.3d 1049, 1070-71 (Pa. 2019) (“In light of the substantial physical evidence establishing [a]ppellant as the perpetrator of these crimes, we conclude that the trial court’s error in denying [a]ppellant’s motion to suppress the statements he made in his videotaped interview was harmless”); (Footnote Continued Next Page) - 17

2024“In other words, an error cannot be harmless if there is a reasonable possibility the error might have contributed to the conviction.” Id. (citation omitted).

2024In other words, an error cannot be harmless if there is a reasonable possibility the error might have contributed to the conviction.” Commonwealth v. Wright, 961 A.2d 119, 143 (Pa. 2008). - 18 - J-S21003-24 As we have concluded the search warrant to be invalid and unsupported by probable cause, the logical conclusion is that the resulting evidence was seized unlawfully as fruit of the poisonous tree.

2019In other words, an error cannot be harmless if there is a reasonable possibility the error might have contributed to the conviction.” Cooley, 118 A.3d at 380 (citation omitted); see also Commonwealth v. Mitchell, 576 Pa. 258 , 839 A.2d 202 , 214– 15 (2003) (“An error will be deemed harmless where the appellate court concludes beyond a reasonable doubt that the error could not have contributed to the verdict.”). - 11 - J-A22002-19 Harmless error exists where: (1) the error did not prejudice the defendant or the prejudice was de minimis; (2) the erroneously admitted evidence was merely cumulativ

2018In other words, an error cannot be harmless if there is a reasonable possibility the error might have contributed to the conviction." Cooley , 118 A.3d at 380 (citation omitted); see also Commonwealth v. Mitchell , 576 Pa. 258 , 839 A.2d 202 , 214-15 (2003) ("An error will be deemed harmless where the appellate court concludes beyond a reasonable doubt that the error could not have contributed to the verdict.").

2015Commonwealth v. Northrip, 945 A.2d 198, 203 (Pa. Super. 2008) (citations and formatting omitted).

2015Commonwealth v. Northrip, 945 A.2d 198, 203 (Pa. Super. 2008) (citations and formatting omitted).

2025Commonwealth v. Yocolano, 169 A.3d 47, 53 (Pa. Super. 2017) (citation omitted).

2018“An error is harmless if it could not have contributed to the [decision], or stated -9- J-A26027-17 conversely, an error cannot be harmless if there is a reasonable possibility the error might have contributed to the [decision].” Commonwealth v. Yocolano, 169 A.3d 47, 53 (Pa. Super. 2017).

2022See id.; See also Commonwealth v. Fulton, 179 A.3d 475, 493 (Pa. 2018) (noting that “[w]henever there is a reasonable possibility that an error might have contributed to the conviction, the error is not harmless” (citation and quotation marks omitted)); Commonwealth v. Aponte, 855 A.2d 800 , 811 n.12 (Pa. 2004) (noting that “[e]vidence of prior criminal activity . . . is probably only equaled by a confession in its prejudicial impact upon a jury” (citation omitted)).

2020See Commonwealth v. Fulton, 179 A.3d 475, 493 (Pa. 2018) (“Whenever there is a reasonable possibility that an error might have contributed to the conviction, the error is not harmless.”) (quoting Commonwealth v. Story, 383 A.2d 155, 164 (Pa. 1978)).

2016In other words, an error cannot be harmless if ____________________________________________ 7 Appellant did not call any witnesses or offer any evidence in his defense. 8 “The harmless error doctrine, as adopted in Pennsylvania, reflects the reality that the accused is entitled to a fair trial, not a perfect trial.” Commonwealth v. Reese, 31 A.3d 708, 719 (Pa. Super. 2011) (en banc) (citation omitted). -8- J-S26022-16 there is a reasonable possibility the error might have contributed to the conviction.” Cooley, A.3d at 380 (citation omitted); see also Commonwealth v. Mitchell, 839 A.2d 202, 21

2015In other words, an error cannot be harmless if there is a reasonable possibility the error might have contributed ____________________________________________ 4 “The harmless error doctrine, as adopted in Pennsylvania, reflects the reality that the accused is entitled to a fair trial, not a perfect trial.” Commonwealth v. Reese, 31 A.3d 708, 719 (Pa. Super. 2011) (en banc) (citation omitted). -6- J-S34041-15 to the conviction.” Cooley, 2015 WL 4068720 , at *8 (citation omitted); see also Commonwealth v. Mitchell, 839 A.2d 202, 214-15 (Pa. 2003) (“An error will be deemed harmless where the appe

1995See also: Commonwealth v. Crews, 536 Pa. 508, 529-530 , 640 A.2d 395, 405-406 (1994); Commonwealth v. Lewis, 528 Pa. 440, 451 , 598 A.2d 975, 980-981 (1991).

1995See also: Commonwealth v. Crews, 536 Pa. 508, 529-530 , 640 A.2d 395, 405-406 (1994); Commonwealth v. Lewis, 528 Pa. 440, 451 , 598 A.2d 975, 980-981 (1991).

1995Whenever there is a reasonable possibility that an error might have contributed to the conviction, the error is not harmless.” Commonwealth v. Rush, 529 Pa. 498, 503 , 605 A.2d 792, 794 (1992), citing Commonwealth v. Story, 476 Pa. 391, 409 , 383 A.2d 155, 164 (1978).

1995Whenever there is a reasonable possibility that an error might have contributed to the conviction, the error is not harmless.” Commonwealth v. Rush, 529 Pa. 498, 503 , 605 A.2d 792, 794 (1992), citing Commonwealth v. Story, 476 Pa. 391, 409 , 383 A.2d 155, 164 (1978).

2024“When there is a reasonable possibility that an error might have contributed to the conviction, the error is not harmless.” Commonwealth v. Mullins, 665 A.2d 1275, 1279 (Pa. Super. 1995).

2024Commonwealth v. Mullins, 665 A.2d 1275 , 1275–1278 (Pa. Super. 1995) (internal citations, quotations, original brackets, and footnote omitted).

1994Commonwealth v. Davis, 452 Pa. 171 , 305 A.2d 715 (1973).

1994Commonwealth v. Davis, 452 Pa. 171 , 305 A.2d 715 (1973).

2025Stated differently, “harmless error exists if the record demonstrates, inter alia, that the erroneously admitted evidence was merely cumulative of other untainted evidence which was substantially similar to the erroneously admitted evidence, or that the properly admitted and uncontradicted evidence of guilt was so overwhelming and the prejudicial effect of the error was so insignificant by comparison that the error could not have contributed to the verdict.” Commonwealth v. Copenhaver, 316 A.3d 1020, 1025 (Pa. Super. 2024), appeal denied, 330 A.3d 1248 (Pa. 2024).

2025See Commonwealth v. Hamlett, 234 A.3d 486 , 492 (Pa. 2020) (“sua sponte invocation of the harmless error doctrine is not inappropriate as it does nothing more than affirm a valid judgment of sentence on an alternative basis”) (citation omitted); Commonwealth v. Frein, 206 A.3d 1049, 1070-71 (Pa. 2019) (“In light of the substantial physical evidence establishing [a]ppellant as the perpetrator of these crimes, we conclude that the trial court’s error in denying [a]ppellant’s motion to suppress the statements he made in his videotaped interview was harmless”); (Footnote Continued Next Page) - 17

2024See Santiago, supra. As such, all of the evidence seized as a result of the above-described search warrant must be suppressed.

2020Commonwealth v. DeJesus, 880 A.2d 608, 614 (Pa. 2005) (citation omitted and some formatting altered).

2020Commonwealth v. Rivera, 597 A.2d 690, 694 (Pa. Super. 1991).

2019Commonwealth v. Hutchinson, 571 Pa. 45 , 811 A.2d 556, 561 (2002) (citation omitted).

2019Commonwealth v. Hutchinson, 571 Pa. 45 , 811 A.2d 556, 561 (2002) (citation omitted).

2019See, e.g., Commonwealth v. LaRosa, 626 A.2d 103, 108 (Pa. 1993) (“Whenever there is a reasonable possibility that an error might have contributed to the conviction, the error is not harmless.”) (cleaned up).

2015Commonwealch v. Passmore, 857 A. 2d 697, 711 (Pa. Super.

2012Id. at 155.

2003This Court has held that in certain circumstances, permitting a jury to deliberate with a non-exhibit is per se prejudicial, see Commonwealth v. Karaffa, 551 Pa. 173 , 709 A.2d 887, 889-90 (1998) (deliberations with written jury instructions is per se prejudicial), but I agree with the majority that deliberation with the diagram here should be analyzed under a harmless error standard, as the diagram was neither inherently prejudicial nor explicitly prohibited by Rule 646(B). [1] That said, I firmly disagree *890 with the majority that the jury's deliberation with the diagram constituted harmle

2003This Court has held that in certain circumstances, permitting a jury to deliberate with a non-exhibit is per se prejudicial, see Commonwealth v. Karaffa, 551 Pa. 173 , 709 A.2d 887, 889-90 (1998) (deliberations with written jury instructions is per se prejudicial), but I agree with the majority that deliberation with the diagram here should be analyzed under a harmless error standard, as the diagram was neither inherently prejudicial nor explicitly prohibited by Rule 646(B). [1] That said, I firmly disagree *890 with the majority that the jury's deliberation with the diagram constituted harmle