How does the harmless error standard apply in a civil case?

California, United States of America


The following excerpt is from People v. Scott, E063543 (Cal. App. 2017):

Defendant contends the harmless error standard of Chapman v. California (1967) 386 U.S. 18, 24, applies because the prior conviction evidence violated his federal Constitutional rights to a fair trial and due process. "To prove a deprivation of federal due process rights, [defendant] must satisfy a high constitutional standard to show that the erroneous admission of evidence resulted in an unfair trial. 'Only if there are no permissible inferences the jury may draw from the evidence can its admission violate due process. Even then, the evidence must "be of such quality as necessarily prevents a fair trial." [Citations.] Only under such circumstances can it be inferred that the jury must have used the evidence for an improper purpose.' [Citation.] 'The dispositive issue is . . . whether the trial court committed an error which rendered the trial "so 'arbitrary and fundamentally unfair' that it violated federal due process."'" (People v. Albarran (2007) 149 Cal.App.4th 214, 229-230, fn. omitted.) Any error in this case did not meet this standard.

Page 14

The judgment is affirmed.

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