Case law · Highest court · Federal

Harrington v. California

Decided
June 2, 1969
Docket
750
Status
Published
Jurisdiction
Federal

Cited 2,732 timesNo negative treatment found in this library

What later courts said

  • concluding that because “the case against [the defendant] was so overwhelming” the error “was harmless beyond a reasonable doubt” — Government of the Virgin Islands v. Davis (2009)
  • holding that the defendant's inability to cross-examine his co-defendants who chose not to take the stand was harmless error — State v. Rhodes (2011)
  • recognizing that cumulative nature of contested evidence is a factor that contributes to the conclusion that any error in admitting the evidence was harmless — United States v. Owens (2019)

Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.

How the opinion begins

Mr. Justice Douglas delivered the opinion of the Court.

We held in Chapman v. California, 386 U. S. 18, that “before 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.” Id., at 24. We said that, although “there are some constitutional rights so basic to a fair trial that their infraction can never be treated as harmless error” (id., at 23), not all [*252] “trial errors which violate the Constitution automatically call for reversal.” Ibid.

The question whether the alleged error in the present case was “harmless” under the rule of Chapman arose in a state trial for attempted robbery and first-degree murder. Four men were tried together — Harrington, a Caucasian, and Bosby, Rhone, and Cooper, Negroes— over an objection by Harrington that his trial should be severed. Each of his three codefendants confessed and their confessions were introduced at the trial with limiting instructions that the jury was to consider each confession only against the confessor. Rhone took the stand and Harrington’s counsel cross-examined him. The other two did not take the stand.[1]

Cite this

Harrington v. California, 395 U.S. 250 (1969)

Read the full opinion

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