Whether an appeals court can conclude that a Fourth Amendment error is harmless beyond a reasonable doubt without juxtaposing the error's prejudicial effect against the independent evidence of the defendant's guilt

QUESTION PRESENTED In Chapman v. California, this Court held that a constitutional error is harmless beyond a reasonable doubt if “there was [no] reasonable possibility that the evidence complained of might have contributed to the conviction.” 386 U.S. 18, 24 (1967) (quoting Fahy v. Connecticut, 375 U.S. 85, 86-87 (1968)). It has been suggested by this Court—and explicitly stated by several circuits—that an appeals court must evaluate certain factors to decide whether a constitutional error was, in fact, harmless: 1. the overall strength of the government’s case without the tainted evidence, 2. the government’s conduct with respect to the improperly admitted evidence, and 3. the materiality of the wrongly admitted evidence. To decide whether the error had a prejudicial effect on the jury’s verdict, a court must examine the importance of the improperly admitted evidence and the government’s conduct with respect to that evidence. The court then juxtaposes the error’s prejudicial effect with the independent evidence of the defendant’s guilt. After this comparison, a court can i declare whether the constitutional error was harmless beyond a reasonable doubt. However, there is a split among courts about whether the Chapman approach is necessary. Some courts, like the court below, believe the only thing that matters is whether the government’s overall case is strong without the tainted evidence. The question presented is: Whether an appeals court can conclude that a Fourth Amendment error is harmless beyond a reasonable doubt without juxtaposing the error’s prejudicial effect against the independent evidence of the defendant’s guilt. ii