People v. Gunner, 21 N.Y.2d 732 (1968)
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The admission of evidence obtained in potential violation of the Fourth Amendment may be deemed harmless error if the evidence played a peripheral and insignificant role in the case, particularly when strong independent evidence of guilt exists.
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Summary
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The New York Court of Appeals reconsidered its prior affirmance of the defendant’s robbery conviction in light of Chapman v. California, focusing on whether the admission of a hat and overcoat seized from the defendant’s home, potentially in violation of the Fourth Amendment, constituted harmless error. The court held that the admission of the hat and overcoat was harmless beyond a reasonable doubt, as the complaining witness’s clear and direct identification of the defendant was the primary evidence, and the clothing played a minimal role in establishing guilt.
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Facts
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During a robbery, the complaining witness observed the defendant for approximately 45 minutes.r
Following his arrest, the witness identified the defendant in a police lineup.r
Police found a hat and overcoat in the defendant’s home shortly after his arrest.r
At trial, the prosecution introduced the hat and overcoat as evidence.r
The complaining witness testified that the hat and overcoat were “exactly like” the ones the perpetrator wore, but she did not definitively identify them as the specific items worn during the robbery.r
The defendant argued that the hat and overcoat were seized unlawfully and should not have been admitted as evidence.r
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Procedural History
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The defendant was convicted of robbery, and the New York Court of Appeals initially affirmed the conviction (15 N.Y.2d 778 [1965]).r
Reargument was granted (20 N.Y.2d 970) to consider the impact of Chapman v. California on the judgment.r
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Issue(s)
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Whether the admission of the hat and overcoat, even if obtained in violation of the Fourth Amendment, constituted harmless error under the standard articulated in Chapman v. California.r
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Holding
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Yes, because the hat and overcoat played a peripheral role in the case, and the complaining witness’s direct identification of the defendant provided overwhelming evidence of guilt; therefore, their admission was harmless beyond a reasonable doubt.r
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Court’s Reasoning
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The Court of Appeals applied the harmless error standard articulated in Chapman v. California, which requires a determination of whether the error was harmless beyond a reasonable doubt.r
The court emphasized the importance of the complaining witness’s clear and attentive observation of the defendant during the robbery and her subsequent identification of him at the police lineup. The witness’s identification was considered the primary evidence linking the defendant to the crime.r
The court found that the hat and overcoat played a