whether-the-sixth-circuit's-ruling-merits-summary-reversal

QUESTIONS PRESENTED I. Whether the Sixth Circuit’s ruling merits summary reversal where the court found constitutional error but deemed it harmless under the far less searching standard applied to non-constitutional errors. II. When a district court erroneously refuses to instruct the jury about the effect of the statute of limitations in a criminal trial, is the proper remedy on direct review of a conviction: (1) to reverse for a new trial unless the error is deemed harmless in accordance with the “beyond a reasonable doubt” standard of Chapman v. California, 386 U.S. 18 (1967) (the rule suggested by this Court’s precedent but not yet applied in any circuit court), (2) to presume prejudice, reverse the conviction, and conduct a new trial (the rule in the Fifth, Eleventh, and D.C. Circuits), or (3) to reverse for a new trial unless the error is deemed harmless in accordance with the standard governing non-constitutional errors (the rule in the Sixth Circuit)?