federal constitutional harmless error (California) · Go Syfert
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federal constitutional harmless error in California

9 California opinions name it 2 courts 1977–2023 1 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
People v. Watsongreen
cal · 1956 · cited in 5 California opinions naming this issue, 1977–2023
2 sentences

2023VI, § 13; §§ 1258, 1404), an error is prejudicial only if “it is reasonably probable that a result more favorable to the appealing party would have been reached in the absence of the error.” (People v. Watson (1956) 46 Cal.2d 818, 836 ; see also People v. Young (2019) 7 Cal.5th 905, 931 [admission of irrelevant evidence and unduly prejudicial evidence].) Defendant asserts that the error violated his federal constitutional rights, thus triggering the higher federal constitutional harmless error standard. “‘[T]he admission of 8 Defendant claims the rifle was found in a locked safe.

2016(See, People v. Boyer (2006) 38 Cal.4th 412, 475 .) Defendant contends that we must apply the federal constitutional harmless error standard from Chapman v. California (1967) 386 U.S. 18 , 24—i.e., the prosecution must show that the error was harmless beyond a reasonable doubt—although he acknowledges that under People v. Beltran (2013) 56 Cal.4th 935, 955 , a nonconstitutional claim of misdirection of the jury is reviewed under the California harmless error standard as established in People v. Watson (1956) 46 Cal.2d 818, 836 .

25
Chapman v. Californiayellow
scotus · 1967 · cited in 6 California opinions naming this issue, 1993–2019
2 sentences

2016(See, People v. Boyer (2006) 38 Cal.4th 412, 475 .) Defendant contends that we must apply the federal constitutional harmless error standard from Chapman v. California (1967) 386 U.S. 18 , 24—i.e., the prosecution must show that the error was harmless beyond a reasonable doubt—although he acknowledges that under People v. Beltran (2013) 56 Cal.4th 935, 955 , a nonconstitutional claim of misdirection of the jury is reviewed under the California harmless error standard as established in People v. Watson (1956) 46 Cal.2d 818, 836 .

2000(Maj. opn., ante, at p. 264.) Yet the majority concludes that, on the facts of this case, the erroneous exclusion of defendant and his counsel from the jury selection hearing was harmless under state law (People v. Watson (1956) 46 Cal.2d 818, 836 [ 299 P.2d 243 ] (Watson)) and under the stricter federal constitutional harmless error standard of Chapman v. California (1967) 386 U.S. 18, 24 [ 87 S.Ct. 824, 828 , 17 L.Ed.2d 705 , 24 A.L.R.3d 1065 ] (Chapman).

16
People v. Younggreen
cal · 2019 · cited in 1 California opinions naming this issue, 2023–2023
1 sentence

2023VI, § 13; §§ 1258, 1404), an error is prejudicial only if “it is reasonably probable that a result more favorable to the appealing party would have been reached in the absence of the error.” (People v. Watson (1956) 46 Cal.2d 818, 836 ; see also People v. Young (2019) 7 Cal.5th 905, 931 [admission of irrelevant evidence and unduly prejudicial evidence].) Defendant asserts that the error violated his federal constitutional rights, thus triggering the higher federal constitutional harmless error standard. “‘[T]he admission of 8 Defendant claims the rifle was found in a locked safe.

11
People v. Ayalagreen
cal · 2000 · cited in 1 California opinions naming this issue, 2000–2000
2 sentences

2000(Maj. opn., ante, at p. 544, 6 P.3d at p. 204.) First, the majority's application of the test for harmless error is suspect.

2000(Maj. opn., ante, 99 Cal.Rptr.2d at p. 544 , 6 P.3d at p. 204.) Yet the majority concludes that, on the facts of this case, the erroneous exclusion of defendant and his counsel from the jury selection hearing was harmless under state law ( People v. Watson (1956) 46 Cal.2d 818, 836 , 299 P.2d 243 ( Watson) ) and under the stricter federal constitutional harmless error standard of Chapman v. California (1967) 386 U.S. 18, 24 , 87 S.Ct. 824 , 17 L.Ed.2d 705 ( Chapman ).

11
Arizona v. Fulminantegreen
scotus · 1991 · cited in 1 California opinions naming this issue, 1993–1993
2 sentences

1993In Fulminante , Chief Justice Rehnquist’s opinion noted the numerous, recent federal Supreme Court decisions that have applied the federal constitutional harmless-error rule in a great variety of contexts (id. at pp. 306-307 [113 L.Ed.2d at pp. 329-330, 111 S.Ct. at p. 1263 ] [citing 16 decisions]), and concluded that, as in those cases, the erroneous admission of a coerced confession properly should be treated as a “trial error,” subject to the ordinary federal harmless-error test of Chapman v. California, supra, 386 U.S. 18 , rather than as a “structural defect” that affects the framework wi

1993As a result of the Fulminante decision, supra, 499 U.S. 279 , however, the governing federal constitutional rule now has changed. (3) In Fulminante , Chief Justice Rehnquist's opinion noted the numerous, recent federal Supreme Court decisions that have applied the federal constitutional harmless-error rule in a great variety of contexts ( id. at pp. 306-307 [113 L.Ed.2d at pp. 329-330, 111 S.Ct. at p. 1263 ] [citing 16 decisions]), and concluded that, as in those cases, the erroneous admission of a coerced confession properly should be treated as a "trial error," subject to the ordinary federa

11
Coleman v. Alabamagreen
scotus · 1970 · cited in 1 California opinions naming this issue, 1977–1977
2 sentences

1977(People v. Ruiz (1968) 263 Cal.App.2d 216, 226-228 [ 69 Cal.Rptr. 473 ].) This holding was recognized and reiterated in People v. Johnson (1970) 13 Cal.App.3d 1, 4 [ 91 Cal.Rptr. 203 ], but as that case concerned the right to self-representation at a preliminary hearing rather than at trial the court instead adopted a “harmless error” test. {Id. at p. 5.) Since it had been held that the federal constitutional harmless error doctrine applies to the right to counsel at preliminary hearings (see Coleman v. Alabama (1970) 399 U.S. 1, 10-11 ; 18 [ 26 L.Ed.2d 387, 397-398, 401 , 90 S.Ct. 1999 ]) it

1977(People v. Ruiz (1968) 263 Cal.App.2d 216, 226-228 [ 69 Cal.Rptr. 473 ].) This holding was recognized and reiterated in People v. Johnson (1970) 13 Cal.App.3d 1, 4 [ 91 Cal.Rptr. 203 ], but as that case concerned the right to self-representation at a preliminary hearing rather than at trial the court instead adopted a “harmless error” test. {Id. at p. 5.) Since it had been held that the federal constitutional harmless error doctrine applies to the right to counsel at preliminary hearings (see Coleman v. Alabama (1970) 399 U.S. 1, 10-11 ; 18 [ 26 L.Ed.2d 387, 397-398, 401 , 90 S.Ct. 1999 ]) it

11
People v. Johnsongreen
calctapp · 1970 · cited in 1 California opinions naming this issue, 1977–1977
2 sentences

1977(People v. Ruiz (1968) 263 Cal.App.2d 216, 226-228 [ 69 Cal.Rptr. 473 ].) This holding was recognized and reiterated in People v. Johnson (1970) 13 Cal.App.3d 1, 4 [ 91 Cal.Rptr. 203 ], but as that case concerned the right to self-representation at a preliminary hearing rather than at trial the court instead adopted a “harmless error” test. {Id. at p. 5.) Since it had been held that the federal constitutional harmless error doctrine applies to the right to counsel at preliminary hearings (see Coleman v. Alabama (1970) 399 U.S. 1, 10-11 ; 18 [ 26 L.Ed.2d 387, 397-398, 401 , 90 S.Ct. 1999 ]) it

1977(People v. Ruiz (1968) 263 Cal.App.2d 216, 226-228 [ 69 Cal.Rptr. 473 ].) This holding was recognized and reiterated in People v. Johnson (1970) 13 Cal.App.3d 1, 4 [ 91 Cal.Rptr. 203 ], but as that case concerned the right to self-representation at a preliminary hearing rather than at trial the court instead adopted a “harmless error” test. {Id. at p. 5.) Since it had been held that the federal constitutional harmless error doctrine applies to the right to counsel at preliminary hearings (see Coleman v. Alabama (1970) 399 U.S. 1, 10-11 ; 18 [ 26 L.Ed.2d 387, 397-398, 401 , 90 S.Ct. 1999 ]) it

11
People v. Ruizgreen
calctapp · 1968 · cited in 1 California opinions naming this issue, 1977–1977
2 sentences

1977(People v. Ruiz (1968) 263 Cal.App.2d 216, 226-228 [ 69 Cal.Rptr. 473 ].) This holding was recognized and reiterated in People v. Johnson (1970) 13 Cal.App.3d 1, 4 [ 91 Cal.Rptr. 203 ], but as that case concerned the right to self-representation at a preliminary hearing rather than at trial the court instead adopted a “harmless error” test. {Id. at p. 5.) Since it had been held that the federal constitutional harmless error doctrine applies to the right to counsel at preliminary hearings (see Coleman v. Alabama (1970) 399 U.S. 1, 10-11 ; 18 [ 26 L.Ed.2d 387, 397-398, 401 , 90 S.Ct. 1999 ]) it

1977(People v. Ruiz (1968) 263 Cal.App.2d 216, 226-228 [ 69 Cal.Rptr. 473 ].) This holding was recognized and reiterated in People v. Johnson (1970) 13 Cal.App.3d 1, 4 [ 91 Cal.Rptr. 203 ], but as that case concerned the right to self-representation at a preliminary hearing rather than at trial the court instead adopted a “harmless error” test. {Id. at p. 5.) Since it had been held that the federal constitutional harmless error doctrine applies to the right to counsel at preliminary hearings (see Coleman v. Alabama (1970) 399 U.S. 1, 10-11 ; 18 [ 26 L.Ed.2d 387, 397-398, 401 , 90 S.Ct. 1999 ]) it

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
People v. Harris green
cal · 1994
2 sentences

2019Under that standard, an error must be deemed prejudicial unless it is shown “beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” (Chapman v. California (1967) 386 U.S. 18, 24 .) Thus, an instructional error is harmless when “the evidence . . . is ‘of such compelling force as to show beyond a reasonable doubt’ that the erroneous instruction ‘must have made no difference in reaching the verdict obtained.’ [Citation.]” (People v. Harris (1994) 9 Cal.4th 407, 431 , fn. omitted.) Here, for the reasons already discussed, the evidence was overwhelming t

2019Under that standard, an error must be deemed prejudicial unless it is shown "beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained." ( Chapman v. California (1967) 386 U.S. 18 , 24, 87 S.Ct. 824 , 17 L.Ed.2d 705 .) Thus, an instructional error is harmless when "the evidence ... is 'of such compelling force as to show beyond a reasonable doubt' that the erroneous instruction 'must have made no difference in reaching the verdict obtained.' [Citation.]" ( People v. Harris (1994) 9 Cal.4th 407 , 431, 37 Cal.Rptr.2d 200 , 886 P.2d 1193 , fn. omitted.) Her

22019–2019
People v. Tran green
cal · 2022
1 sentence

2023The evidence showed that it was found in a safe but not that the safe was locked. 13 evidence, even if erroneous under state law, results in a due process violation only if it makes the trial fundamentally unfair.’ [Citation.]” (People v. Tran (2022) 13 Cal.5th 1169 , 1209.) And if the admission of the evidence was harmless under the state-law standard, then we can hardly say that the resulting trial was fundamentally unfair.

12023–2023
People v. Boyer yellow
cal · 2006
1 sentence

2016(See, People v. Boyer (2006) 38 Cal.4th 412, 475 .) Defendant contends that we must apply the federal constitutional harmless error standard from Chapman v. California (1967) 386 U.S. 18 , 24—i.e., the prosecution must show that the error was harmless beyond a reasonable doubt—although he acknowledges that under People v. Beltran (2013) 56 Cal.4th 935, 955 , a nonconstitutional claim of misdirection of the jury is reviewed under the California harmless error standard as established in People v. Watson (1956) 46 Cal.2d 818, 836 .

12016–2016
People v. Beltran green
cal · 2013
1 sentence

2016(See, People v. Boyer (2006) 38 Cal.4th 412, 475 .) Defendant contends that we must apply the federal constitutional harmless error standard from Chapman v. California (1967) 386 U.S. 18 , 24—i.e., the prosecution must show that the error was harmless beyond a reasonable doubt—although he acknowledges that under People v. Beltran (2013) 56 Cal.4th 935, 955 , a nonconstitutional claim of misdirection of the jury is reviewed under the California harmless error standard as established in People v. Watson (1956) 46 Cal.2d 818, 836 .

12016–2016
People v. Avitia green
calctapp · 2005
1 sentence

2014Code, § 353, subd. (b); [citations.]” (People v. Avitia, supra, 127 Cal.App.4th at p. 194 .) Appellant argues the standard is harmless beyond a reasonable doubt pursuant to the federal constitutional harmless-error standard.

12014–2014
People v. Sharp green
cal · 1972
2 sentences

1977(People v. Johnson, supra, at pp. 4-5 .) On the other hand, in People v. Sharp (1972) 7 Cal.3d 448 [ 103 Cal.Rptr. 233 , 499 P.2d 489 ], which was overruled in Faretta, our Supreme Court held that where an accused had made a less than compelling showing of his competence to represent himself, the deprivation of that then non constitutional right was to be reviewed under the lesser standard of People v. Watson (1956) 46 Cal.2d 818, 836 [ 299 P.2d 243 ], (People v. Sharpe, supra, 7 Cal.3d at pp. 462-463.) *356 The Faretta court, without discussing the appropriate standard of reversible error, or

1977(People v. Johnson, supra, at pp. 4-5 .) On the other hand, in People v. Sharp (1972) 7 Cal.3d 448 [ 103 Cal.Rptr. 233 , 499 P.2d 489 ], which was overruled in Faretta, our Supreme Court held that where an accused had made a less than compelling showing of his competence to represent himself, the deprivation of that then non constitutional right was to be reviewed under the lesser standard of People v. Watson (1956) 46 Cal.2d 818, 836 [ 299 P.2d 243 ], (People v. Sharpe, supra, 7 Cal.3d at pp. 462-463.) *356 The Faretta court, without discussing the appropriate standard of reversible error, or

11977–1977

Statutes the citing opinions construe

CA § Cal. Penal Code § 187 (5) CA § Cal. Evidence Code § 352 (3) CA § Cal. Penal Code § 12022.5 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

KS 30 (2007–2026) CA 9 (1977–2023) UT 5 (1988–1989) VA 3 (2000–2011) IN 3 (1995–2014)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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