Cited by

See State v. Juarez , –93 (Minn. 1997) (explaining that the persuasive value of erroneously admitted evidence was undermined in a child -sexual-assault case where the child -victims testified consistently at trial with their earlier statements to investigators and other adults).

to the basis on which the jury actually rested its verdict.” –92 (Minn. 1997) (quoting Sullivan v. Louisiana, 508 U.S. 275, 279 (1993)).

to the basis on which the [fact-finder] actually rested its verdict.” (quoting Sullivan v. Louisiana, 508 U.S. 275, 279 (1993)) “The inquiry, in other words is not whether, in a trial that occurred without the error, a guilty verdict would surely have been rendered, but whether the guilty verdict actually rendered in this trial was surely unattributable to the erro

Stated differently, we must determine “whether there is a reasonable possibility that the evidence complained of might have contributed to the conviction.” (citation omitted) (internal quotation marks omitted).

“The overwhelming evidence of guilt is a factor, often a very important one, in determining whether, beyond a reasonable doubt, the error has no impact on the verdict.”

Strong Evidence of Guilt Finally, “overwhelming evidence of guilt is a factor, often a very important one, in determining whether, beyond a reasonable doubt, the error has no impact on the verdict.”

It is well -established that “[a] defendant’s choice to exercise his constitutional right to counsel may not be used against him at trial.” ().

“An error is harmless beyond a reasonable doubt if the guilty verdict actually rendered was ‘surely unattributable’ to the error.” ().

“[O]verwhelming evidence of guilt is a factor, often a very important one, in determining whether, beyond a reasonable doubt, the error has no impact on the verdict.” d 286, 291 (Minn. 1997).

(noting that a conviction will stand if “the error is harmless beyond a reasonable doubt”).

Caulfield, d at 314; see also Chapman v. California, 386 U.S. 18, 24 (1967) (stating 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”).

(“The overwhelming evidence of guilt is a factor, often a very important one, in determining whether, beyond a reasonable doubt, the error has no impact on the verdict.”).

(quotation omitted); - 91 (Minn. 1997) (holding that it was error for a jury to be informed of a defendant’s request for counsel because the jury may have treated the request as a “badge of guilt”).

“[T]he question is 22 whether there is a reasonable possibility that the evidence complained of might have contributed to the conviction.” (quoting Chapman v. California, 386 U.S. 18, 23 (1967)).

Caulfield, d at 314 (quoting State v. Juarez , and State v. Al-Naseer , ).4 In determining whether the verdict was surely unattributable to an error, we examine the record as whole, consid ering the following five factor s: (1) how th e evidence was presented; (2) whether the evidence was “highly persuasive”

We must “look to the basis on which the [factfinder] rested its verdict and determine what effect the error had on the actual verdict.” Townsend v. State , (citation omitted) (internal quotation marks omitted); (explaining that the harmless error analysis is “better labelled as ‘harmless error impact analysis,’ because it is the impact of that error that the appellate court must consider”).

An error is harmless beyond a reasonable doubt if the “verdict was surely unattributable to the erroneous admission.”

n a district court erroneously joins separate offenses, we remand for separate proceedings only when the error is “prejudicially erroneous.” d 451, 460 (Minn. 1999); see also State v. Kates , -31 (Minn. 2000) (clarifying that for purposes of joinder, we do not apply the “harmless beyond a reasonable doubt” ).

State v. Juarez , , 291 (Minn. 1997).

State v. Juarez , , 291 (Minn. 1997) (providing that an error does not mandate reversal and a new trial if this court determines that the error "was harmless beyond a reasonable doubt").

If the verdict actually rendered was surely unattributable to the error, the error is harmless beyond a reasonable doubt.” (quotation omitted).

impacted upon the jury’s decision.” d 286, 292 (Minn. 1997).

This standard requires us to determine whether the verdict was “surely unattributable to the error.”

An error is harmless beyond a reasonable doubt if the jury verdict is “surely unattributable to the error.” (quotation omitted).

The relevant inquiry “is not whether, in a trial that occurred without the error, a guilty verdict would surely have been rendered, but whether the guilty verdict 9 actually rendered in this trial was surely unattributable to the error.” (quotation omitted).

See, 379 (Minn.1999) (concluding that an improper restraint violated the defendant’s right to a fair trial but was harmless beyond a reasonable doubt); 293 (Minn.1997) (concluding that admission of a statement obtained in violation of the Fifth Amendment was harmless beyond a reasonable doubt).