United States v. Leroy Harris, Jr.

HEANEY, Circuit Judge,

dissenting.

I respectfully dissent. The trial court erred by admitting evidence of Harris’s prior felony convictions under the Supreme Court’s ruling in Old Chief v. United States, - U.S. -, -, 117 S.Ct. 644, 652, 136 L.Ed.2d 574 (1991). Thus, his conviction can only be affirmed if the government carried its burden of showing that the error infecting the trial was harmless. I do not believe that the government has carried its burden.

We must reverse a conviction where the jury might have been “substantially swayed” by improperly admitted evidence. United States v. Davis, 936 F.2d 352, 355 (8th Cir.1991) (citation omitted). Old Chief dictates that the risk of such prejudice is “substantial whenever the official record offered by the government would be arresting enough to lure a juror into a sequence of bad character reasoning.” Id. at -, 117 S.Ct. at 652. There is little doubt that the introduction of four of Harris’s felony convictions could lead the jury to do this. See United States v. Blake, 107 F.3d 651, 652-53 (8th Cir.1997) (considering evidence of four prior felony convictions with other errors in reversing conviction). Here the government’s case was based solely on circumstantial evidence and controverted testimony.4 Thus, exposing the *832jury to the number and type of Harris’s prior convictions was arresting enough to lure jurors into a sequence of bad character reasoning. See Old Chief, — U.S. at -, 117 S.Ct. at 652.

I am also in complete disagreement with the majority’s assertion that Harris “must establish that the asserted error was not harmless.” Ante at 831 (citing Blake, 107 F.3d at 653). The court’s citation to Blake to support its statement is misplaced because that case states only that “[i]n determining whether evidentiary rule violations require reversal the Court applies the Fed.R.Crim.P. 52(a) harmless error analysis.” Blake, 107 F.3d at 653 (citation omitted). Blake makes no statement whatsoever that a defendant has the burden to show an error was not harmless under Rule 52(a).

The court further attempts to support its contention by citing two cases, neither of which stand for the proposition offered. In United States v. Moore, 129 F.3d 989 (8th Cir.1997), this court properly stated that a party asserting a nonconstitutional error has the burden of demonstrating that his substantial rights were affected by the error. Id. at 990. Stating that a defendant must show the error to have affected “substantial rights” is far afield from requiring the defendant to carry the burden to show the effect to be “not harmless” under Rule 52(a).

In Lowe v. United States, 389 F.2d 108 (8th Cir.1968), we stated that a defendant asserting error has a burden “to show both error and prejudice.” Id. at 112 (quoting Thomas v. United States 281 F.2d 132, 136 (8th Cir.1960)).5 We clarified that statement by explaining that an evidentiary error that would warrant a reversal in a close case “may be disregarded as harmless where the evidence of guilt is strong.” Id. (citation omitted). Lowe simply requires that a defendant asserting error show that the trial court erred in admitting evidence and that the evidence would tend to prejudice the fact finder against the defendant before requiring the reviewing court to consider whether the error was harmless. Neither Moore nor Lowe places the burden on the defendant to show the error was not harmless where the defendant claims nonconstitutional error.

In Darden v. Wainwright, Justice Black-mun stated that:

Every harmless-error standard that [the Supreme] Court has employed ... shares two salient features. First, once serious error has been identified, the burden shifts to the beneficiary of the error to show that the conviction was not tainted. Second, ... the question before a reviewing court is never whether the evidence would have been sufficient to justify conviction, absent an error, but, rather, whether the error undermines its confidence in the outcome of the proceeding to an unacceptable degree.

477 U.S. 168, 197, 106 S.Ct. 2464, 2479, 91 L.Ed.2d 144 (1986) (Blackmun, J., dissenting) (citations omitted). This statement is consistent with Kotteakos v. United States, 328 U.S. 750, 66 S.Ct. 1239, 90 L.Ed. 1557 (1946), where the Supreme Court held that, even where the claimed error is nonconstitutional in nature, if the error’s “natural effect is to prejudice a'litigant’s substantial rights,” the party who benefitted from the error bears the burden of sustaining the verdict. Id. at 760-61, 66 S.Ct. at 1245-46 (citations omitted).

*833Congress passed Rule 52(a) as a restatement of 28 U.S.C. § 391,6 which was enacted to “prevent matters concerned with the mere etiquette of trials and with the formalities and minutiae of procedure from touching the merits of a verdict.” Bruno v. United States, 308 U.S. 287, 294, 60 S.Ct. 198, 200, 84 L.Ed. 257 (1939). The Supreme Court distinguishes a defendant’s right to a trial free from mere technical errors as being “[of] a very different order of importance” than the defendant’s right “to insist on a privilege which Congress has given him,” id., such as the right to be free of overly prejudicial evidence under Federal Rule of Evidence 403.

The majority attempts to defend its errant standard by distinguishing the application of the harmless-error rule in the present ease from those in which the claimed error is constitutional in nature. See Sullivan v. Louisiana, 508 U.S. 275, 278-79, 113 S.Ct. 2078, 2080-81, 124 L.Ed.2d 182 (1993) (constitutional error is harmless if government can show beyond a reasonable doubt that the error did not contribute to the challenged verdict); Seiler v. Thalacker, 101 F.3d 536, 539-40 (8th Cir.1996) (“The state has a heavy burden in proving that [a constitutional] error is harmless beyond a reasonable doubt.”) (citation omitted). I agree that the harmless-error standard for nonconstitutional errors differs from that for constitutional ones, but the difference is that a claim of constitutional error automatically warrants harmless-error review, where a complaining party must show a nonconstitutional error to be more than merely technical to receive such review. In either case, however, the party receiving the benefit of the error carries the burden of showing that the error did not affect the verdict.

In United States v. Hernandez, 109 F.3d 1450, 1453 (9th Cir.1997), the Ninth Circuit correctly applied the standard, holding that the government bears the burden to show harmlessness in a trial court’s error of admitting prior felonies under Old Chief.7 The majority has cited no cases contrary to Hernandez, and I have been unable to find any. In any event, our court must be guided by the decisions of the Supreme Court, which clearly dictate that the beneficiary of the trial court’s error, the government, bears the burden to show that the error was harmless. The government has failed to meet its burden, and for that reason, Harris’s conviction should not stand.

. The evidence upon which the government relied to convict Harris consisted of: controverted testimony of the officers that Harris admitted ownership and of a woman who claimed she saw Harris purchase the gun; testimony that Harris *832periodically lived at the house where police found the gun; and the fact that Harris had a hunting license. The record shows no evidence of Harris's fingerprints on the weapon, see United States v. Hernandez, 109 F.3d 1450, 1453 (9th Cir.1997) (considering a lack of fingerprints on a weapon as a significant factor in determining whether evidence of possession of a weapon was overwhelming), nor did any of the officers see Harris in possession of the weapon.

. Despite our citation of Thomas indicating that a defendant must show error and "prejudice,” it is clear that the burden of persuasion regarding prejudice where the trial court commits noncon-stitutional error rests with the government. See United States v. Olano, 507 U.S. 725, 734-35, 113 S.Ct. 1770, 1777-78, 123 L.Ed.2d 508 (1993) ("harmless error” inquiry under Rule 52(a) differs from "plain error” inquiry under Rule 52(b) in that defendant bears the burden of persuasion with respect to prejudice in claim under plain error rule).

. Section 391 provided, in pertinent part:

On the hearing of any appeal, certiorari, writ of error, or motion for a new trial, in any case, civil or criminal, the court shall give judgment after an examination of the entire record before the court, without regard to technical errors, defects, or exceptions which do not affect the substantial rights of the parties.

28 U.S.C. § 391 (1928).

. The majority dismisses the Ninth Circuit’s holding in Hernandez as being “without cited authority.” Ante at 831, note 3. The likely reason for the absence of citations by our sister circuit is the well-established principle that the beneficiary of a trial court's error bears the burden to show the error was harmless. The line of precedents alluded to by the majority is neither long, nor to the contrary of the rule in Hernandez.