Harrington v. California

1969-06-02

Headline: Court affirms a man’s murder conviction, ruling that two untested codefendants’ confessions were harmless on these facts, leaving the state conviction in place and affecting criminal appeals over confessions.

Holding: The Court affirmed the state conviction, ruling that the admission of two untested codefendant confessions was harmless beyond a reasonable doubt because the untainted evidence against the defendant was overwhelming.

Real World Impact:

Leaves the state murder conviction intact despite admission of codefendants' confessions.
Permits some constitutional trial errors to be deemed harmless when untainted evidence is overwhelming.
Raises concern that defendants may lose relief even when constitutional safeguards were violated.

Topics: codefendant confessions, right to confront witnesses, harmless-error review, joint criminal trials

Summary

Background

A white defendant was tried with three Black codefendants for an attempted robbery that left a store employee dead. Each codefendant gave a confession; two did not testify and their confessions were read to the jury with instructions to consider them only against the confessor. One codefendant testified and was cross-examined; the defendant himself made admissions placing him at the scene and other witnesses also identified him.

Reasoning

The Court considered whether admitting the two confessions without letting the defendant cross-examine those speakers violated the right to confront witnesses and, if so, whether that error was harmless. Applying its prior harmless-error test, the majority concluded that, on these specific facts, the untested confessions were cumulative and that the remaining untainted evidence was so strong the error was harmless beyond a reasonable doubt. The Court therefore left the state conviction undisturbed.

Real world impact

The decision lets this murder conviction stand despite the admission of two codefendant confessions that the defendant could not test by cross-examination. It signals that appellate courts may decide some confrontation errors harmless when other evidence is overwhelming, unless one adopts a view requiring automatic reversal for such errors.

Dissents or concurrances

A dissent warned that this approach undermines Chapman and other criminal procedure protections, arguing it shifts the focus to how much untainted evidence exists rather than the tainted evidence’s effect on the jury.