Does a denial of a belated request for counsel constitute an error that would have been harmless beyond a reasonable doubt?

California, United States of America


The following excerpt is from People v. Carroll, 140 Cal.App.3d 135, 189 Cal.Rptr. 327 (Cal. App. 1983):

Any error related to denial of the belated request for counsel would have been found harmless beyond a reasonable doubt. (See Chapman v. California, supra, 386 U.S. 18, 87 S.Ct. 824, 17 L.Ed.2d 705.)

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