72 N.Y.2d 941 (1988)
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The admission of a codefendant’s statement is harmless error if there is overwhelming independent evidence of the defendant’s guilt and the codefendant’s statement is consistent with the defendant’s own statements, even if the codefendant’s statement shifts blame for a specific action.
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Summary
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West was convicted of second-degree murder committed during a street robbery. He appealed, arguing that the trial court erred by admitting a codefendant’s statement, violating his rights under Cruz v. New York. The Court of Appeals affirmed the conviction, holding that the admission of the codefendant’s statement was harmless error beyond a reasonable doubt. The court emphasized the strong evidence of West’s guilt, including eyewitness testimony, the victim’s dying declaration, and West’s own incriminating statements. The codefendant’s statement, while inconsistent on a minor point, was largely corroborative of West’s involvement in the robbery.
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Facts
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The victim was shot and killed during a street robbery. Three eyewitnesses testified that four youths, including West, approached the victim while he was changing a tire. Two of the youths held the victim while the others attempted to rob him, and during the robbery, the victim was shot. The victim’s dying declaration corroborated this version of events. West initially admitted to police that he was with three others, that one had a gun, and they approached the victim to rob him. He later recanted his initial admission of participating in the robbery, claiming he was standing a few feet away. He still acknowledged being present with the others, knowing about the gun and the intent to rob the victim.
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Procedural History
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West was convicted of second-degree murder. He appealed the conviction based on the admission of the codefendant’s statement. The Appellate Division affirmed the conviction. The New York Court of Appeals then reviewed the case.
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Issue(s)
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Whether the admission of a codefendant’s statement, which is consistent with the defendant’s own statements but shifts blame for a specific action, constitutes harmless error when there is strong independent evidence of the defendant’s guilt.
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Holding
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Yes, because the admission of the codefendant’s statement was harmless beyond a reasonable doubt given the strong independent evidence of West’s guilt, including eyewitness testimony, the victim’s dying declaration, and West’s own incriminating statements.
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Court’s Reasoning
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The Court of Appeals applied the harmless error doctrine, noting that an error is harmless if there is no reasonable possibility that the error contributed to the conviction. The court emphasized the