On Point blog, page 2 of 2
Appellate Procedure – Harmless Error: General Test
State v. Ronell E. Harris, 2008 WI 15, affirming unpublished decision
For Harris: Ralph J. Sczygelskis
Issue/Holding: Various discovery and evidentiary violations amounted to harmless error, whether taken singly (¶¶41-59, ¶87-90) or cumulatively (¶¶109-113).Harmless error discussions are largely fact-specific, and this case is no exception. But it is noteworthy for its recognition that the “court has formulated the test for harmless or prejudicial error in a variety of way,” ¶42.
Appellate Procedure – Harmless Error Analysis, Generally
State v. Thomas S. Mayo, 2007 WI 78, affirming unpublished opinion
For Mayo: Keith A. Findley, UW Law School
Issue/Holding:
¶47 In determining whether a constitutional error is harmless, the inquiry is as follows: “‘Is it clear beyond a reasonable doubt that a rational jury would have found the defendant guilty absent the error?’” State v. Harvey,
Appellate Procedure – Harmless Error – Test, Generally
State v. Paul J. Stuart, 2005 WI 47, reversing unpublished COA opinion; and overruling State v. Paul J. Stuart, 2003 WI 73<
For Stuart: Christopher W. Rose
Issue/Holding:
¶40 The test for this harmless error was set forth by the Supreme Court in Chapman v. California, 386 U.S. 18 (1967), reh’g denied, 386 U.S.