In Arizona v. Fulminante, the United States Supreme Court held that coerced confessions that are erroneously admitted at trial are now subject to the harmless-error rule. The Court's holding is a radical departure from precedent. Consequently, this note examines this precedent and the Fulminante decision. The author concludes that Fulminante has created inconsistency within the area of law dealing with coerced confessions, increased the possibility of unfair trials, and narrowed defendants' due process rights.
College of Law
Northern Illinois University Law Review
Miller, Shawn O.
"Harmful Error: Arizona v. Fulminante and the Expansion of the Harmless-Error Rule,"
Northern Illinois University Law Review: Vol. 12:
2, Article 6.
Shawn O. Miller, Note, Harmful Error: Arizona v. Fulminante and the Expansion of the Harmless-Error Rule, 12 N. Ill. U. L. Rev. 435 (1992).