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If the appellate court cannot say beyond a reasonable doubt that error did not affect the verdict, then the error is by definition harmful.
Defendant John Edward Traylor was charged with second-degree murder of a woman in Florida. He was later apprehended in Alabama, after being arrested and charged with killing a woman there. Defendant was arraigned in Alabama on that charge and counsel was appointed. Florida authorities then came to Alabama and questioned defendant. After being advised of his rights, defendant signed a written waiver and confessed to both murders. His motion to suppress during the Florida prosecution was denied and the jury heard his confession to both murders. He was convicted and the appellate court affirmed, ruling that the admission of the confession to the Alabama murder was harmless error in light of other overwhelming evidence. Defendant appealed, arguing that it was error to find that the use of the confessions was harmless.
Was the use of defendant’s confessions a harmless error?
The decision affirming the conviction was approved, although the district court's standard for harmless error was disapproved, because, with respect to the Florida confession, defendant was adequately informed of his rights and validly waived them without having invoked his privilege against self-incrimination. With respect to the Alabama confession, the Court held that it violated defendant’s right to counsel, but it was harmless error because there was no reasonable doubt it affected the verdict.