Judge RAGGI dissents in a separate opinion.
POOLER, Circuit Judge.Petitioner-Appellant Guy Zappulla appeals from a judgment of the United States District Court for the Eastern District of New York (Weinstein, /.), entered October 10, 2003, denying his petition for a writ of habeas corpus. His petition sought to challenge a judgment of the New York Supreme Court, Kings County (Kreindler, J.), rendered on March 30, 1999, convicting him after a jury trial of murder in the second degree. The New York State Appellate Division, Second Department (“Appellate Division”), affirmed Zappulla’s murder conviction while concluding that the wrongful admission of Zappulla’s confession, taken in violation of his Miranda rights, was harmless error. We find that the Appellate Division applied the harmless error review in an “objectively unreasonable” manner, and that the erroneous admission of his confession requires us to vacate his conviction.
BACKGROUND
The facts of the case are derived largely from the factual account in the district court decision, which in turn was drawn *465from the Appellate Division’s decision affirming Zappulla’s conviction. Zappulla v. New York, 296 F.Supp.2d 309, 311 (E.D.N.Y.2003) (“Zappulla”); People v. Zappulla, 282 A.D.2d 696, 724 N.Y.S.2d 433 (2d Dep’t 2001) (“People ”). On March 17, 1998, at approximately 12:30 a.m.-, Zap-pulla was arrested at the Golden Gate Inn in Brooklyn, New York, based on a police report that he had stolen his girlfriend’s fur coat and jewelry. Zappulla, 296 F.Supp.2d at 311. At the time of his arrest, the arresting officers read him his rights pursuant to Miranda v. Arizona, 384 U.S. 436, 86 S.Ct. 1602, 16 L.Ed.2d 694 (1966), and then attempted to question him about the theft. Zappulla refused to talk about the theft but spoke about other matters. During this time, the police found a motel room key on Zappulla’s person and went to the corresponding room. Inside the room, the police officers discovered the fur coat that was reported stolen and the dead body of a prostitute, Jennifer Scarpa-ti, a.k.a. Jennifer Imparato (“Jennifer”), hidden under one of the motel beds. In the meantime, Zappulla momentarily escaped from police custody and, while attempting to flee, was hit by a car and taken to the hospital. Upon his return to police custody the following day, Zappulla was again questioned, although this time he' was not warned about his Miranda rights and was questioned about the more serious crime of murder. Zappulla initially stated that he wanted a lawyer, and the officers responded, “If you want a lawyer, we can’t speak to you any further.” Zappulla, 296 F.Supp.2d at 312. Zappulla then confessed to the police about the murder .and signed a statement memorializing his confession. In this confession, Zappulla admitted that an individual named “Teamo or Aaron” (a.k.a. Aaron Cohen) rented a motel room for him and he stayed there for three days “getting high.” Jennifer, a close friend of Cohen’s, joined Zappulla at the motel room and smoked crack with him and Cohen. Zappulla’s confession indicated that he later became angry when he realized that Jennifer had stolen jewelry from him to purchase more crack. According to the confession, he then got into an argument with Jennifer about the jewelry, choked her, and left the room.
The trial court rejected Zappulla’s motion to suppress the confession and permitted the prosecutor to use the confession at trial. Zappulla’s first trial for Jennifer’s murder resulted in a mistrial after the jury deliberated for three days without being able to reach a verdict, despite the reading of an Allen charge. At the second trial, the prosecutor relied more heavily on Zap-pulla’s confession, mentioning it as the first piece of evidence in the prosecution’s case. At summation, the prosecutor again discussed the circumstances and details of Zappulla’s confession. The prosecutor emphasized how- the confession was credible and tied in with other evidence in the case and how it provided vital evidence of motive. On March 10, 1999, the court delivered a charge to the jury on intentional murder, and the jury retired to deliberate at approximately 9:30 a.m. The jury requested and received numerous items, including Zappulla’s signed confession. At 5:15 p.m., the jury returned with a verdict, finding Zappulla guilty of intentional murder. On March 30, 1999, the court sentenced Zappulla to a prison term of 25 years to life. .
The Appellate Division affirmed Zappul-la’s conviction on direct appeal even though it found that the trial court erred in admitting Zappulla’s confession. People, 282 A.D.2d at 697, 724 N.Y.S.2d 433. The court found that the confession was defective because 24 hours had elapsed between the initial questioning of Zappulla, where Miranda warnings were given, and the subsequent interrogation, where the *466officers questioned him without Miranda warnings about a different crime and custody was not continuous. The court, however, found that failure to suppress the confession was harmless in light of the “overwhelming evidence of his guilt.” Id. at 698. Specifically, the court found:
A witness testified that the defendant was with [Jennifer] in Room 234 at the Golden Gate Inn in the days and hours immediately before the crime. Surveillance videotape from the motel showed the defendant leaving and then reentering the motel shortly before the police arrived and arrested him on March 17, 1998. Expert testimony indicated that [Jennifer’s] death occurred sometime between the evening of March 16 and the early morning of March 17. The key to Room 234, the room where [Jennifer’s] body was found, was recovered from the defendant’s person after his arrest. D.N.A. testing of blood found on the defendant’s clothing revealed that the blood was [Jennifer’s], In addition, the defendant admitted to an inmate, who was incarcerated with the defendant pending trial, that when he choked [Jennifer] “blood came out.” In light of this overwhelming evidence, there is no reasonable possibility that the error of admitting the defendant’s statement into evidence might have contributed to his conviction.
Id. A judge of the New York Court of Appeals denied Zappulla’s application for leave to appeal. People v. Zappulla, 96 N.Y.2d 909, 730 N.Y.S.2d 808, 756 N.E.2d 96 (2001). No state collateral proceedings were initiated.
Having sufficiently exhausted his avenues for relief under state law, in June 2002, Zappulla, pro se, filed a habeas petition in the district court for the Eastern District of New York. On September 30, 2003, the district court denied Zappulla’s petition by holding that, although the confession was erroneously admitted, admission of the confession was harmless in light of the overwhelming evidence of guilt. Zappulla, 296 F.Supp.2d at 319. In so holding, the district court specifically adopted the reasoning of the Appellate Division, set forth above, with little additional analysis. Id. The district court, however, granted Zappulla a certificate of appealability on the question of whether the erroneous admission of the confession was harmless. Id. at 320. On December 22, 2003, this Court appointed counsel to represent Zappulla in this appeal.
DISCUSSION
“This Court reviews de novo the District Court’s denial of the petition [for habeas corpus].” Francolino v. Kuhlman, 365 F.3d 137, 140 (2d Cir.2004).
I. Harmless Error Standard
Where a confession has been erroneously admitted in violation of the defendant’s Miranda rights, this constitutional error is subject to a harmless error analysis. See Arizona v. Fulminante, 499 U.S. 279, 310, 111 S.Ct. 1246, 113 L.Ed.2d 302 (1991); Brown v. Keane, 355 F.3d 82, 91 (2d Cir.2004) (“A habeas petitioner is entitled to relief only if the constitutional error at trial was not harmless.”).
Prior to the enactment of the Antiter-rorism and Effective Death Penalty Act of 1996 (“AEDPA”), Pub.L. No. 104-132, 110 Stat. 1214, the Supreme Court held in Brecht v. Abrahamson that, on collateral review of a state conviction, an error is harmless if it did not have a “substantial and injurious effect or influence in determining the jury’s verdict.” 507 U.S. 619, 637, 113 S.Ct. 1710, 123 L.Ed.2d 353 (1993) (internal quotation marks omitted). In Chapman v. California, the Court held that on direct review of a criminal convic*467tion, an error may be overlooked only if it is “harmless beyond a reasonable doubt.” 386 U.S. 18, 24, 87 S.Ct. 824, 17 L.Ed.2d 705 (1967). Under AEDPA, a- federal ha-beas court may grant-the writ if the state court’s decision constitutes an “unreasonable application” of “clearly established Federal law, as determined by the Supreme Court of the United States.” 28 U.S.C. § 2254(d)(1). We have previously noted that it remains “an open question in this circuit whether, following the passage of AEDPA, the applicable test on habeas review of a state conviction remains the one set forth in Brecht, or instead should be a determination [of] whether the state court’s decision was contrary to, or involved an unreasonable application of Chapman.” Brown, 355 F.3d at 91 (quoting Noble v. Kelly, 246 F.3d 93, 101 n. 5 (2d Cir.2001)) (internal quotation marks omitted).
Recently, the Supreme Court arguably resolved this uncertainty. Mitchell v. Es-parza, 540 U.S. 12, 124 S.Ct. 7, 157 L.Ed.2d 263 (2003) (per curiam). In Mitchell, the Sixth Circuit considéred whether the death sentence was properly imposed where the State failed to charge in the indictment the aggravating circumstance upon which the death sentence was predicated. Esparza v. Mitchell, 310 F.3d 414, 416 (6th Cir.2002). The trial court likewise failed to instruct the jury on the aggravating circumstance and the jury did not return a verdict that found one or more of the aggravating circumstances. Id. at 416-17. The Sixth Circuit held that it was error to impose the death penalty under such circumstances and that such an error was categorically immune from harmless error review. Id. at 421-22. In reversing the Sixth Circuit, the Supreme Court first found that the trial court’s errors were not immune from harmless error review. Mitchell, 540 U.S. at 16-17, 124 S.Ct. 7. It then held that the Ohio Court of Appeals’ conclusion, that failure to comply with the state death penalty statute .was harmless error, was not objectively unreasonable. Id. at 18, 124 S.Ct. 7. The Court stated that “habeas relief is appropriate - only if the [state] Court of Appeals- applied harmless error review in an ‘objectively unreasonable’ manner.” Id. However, the Court also held that a constitutional error can only be found harmless if “it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” Id. at 17-18, 124 S.Ct. 7. (internal quotation marks omitted).
This case requires us to address what standard governs our review of a district court’s determination that a constitutional error was harmless following the passage of AEDPA.1 We follow, as we must, the Supreme Court’s reasoning in Mitchell to hold that, in reviewing a state court’s harmless error determination, we only may reverse determinations thaf are objectively unreasonable. See id. The pertinent state court determination is whether the People proved “beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” Id. (internal quotation marks omitted).
II. The Appellate Division’s Determination That Admission Of Zappulla’s Confession Was Harmless Error Was An Objectively Unreasonable Application of Supreme Court Precedent
In Arizona v. Fulminante, the Supreme Court considered numerous factors in *468holding that the erroneous admission of a coerced confession had a substantial and injurious effect on the jury’s decision. 499 U.S. 279, 111 S.Ct. 1246, 113 L.Ed.2d 302 (1991). The Court noted that the prosecutor made extensive use of the confession in its opening and closing statement, id. at 297-98, 111 S.Ct. 1246; see also Chapman v. California, 386 U.S. 18, 25, 87 S.Ct. 824, 17 L.Ed.2d 705 (1967), that the confession was a crucial piece of evidence and not merely cumulative of other evidence, Fulminante, 499 U.S. at 296, 299, 111 S.Ct. 1246, and that the prosecution’s case was weak absent inclusion of the confession, id. at 297-99, & 299 n. 9, 111 S.Ct. 1246; see also Chapman, 386 U.S. at 25-26, 87 S.Ct. 824 (observing that an error is less likely to be harmless if the case is a close one). In Satterwhite v. Texas, the Supreme Court held that the erroneous admission of a psychiatrist’s testimony was not harmless error because this testimony appeared to be highly credible, the expert’s testimony was unequivocal and heavily emphasized by the prosecution, and the. expert provided the only piece of evidence on a crucial issue at the sentencing hearing. 486 U.S. 249, 260, 108 S.Ct. 1792, 100 L.Ed.2d 284 (1988).
By distilling these Supreme Court precedents, we conclude that the Supreme Court has found the following factors to be relevant in determining whether the erroneous admission of a confession was harmless error. See also Wray v. Johnson, 202 F.3d 515, 526-27 (2d Cir.2000) (reversing the district court’s determination that the improperly admitted identification evidence was not harmless and discussing relevant factors); see also United States v. Jean-Baptiste, 166 F.3d 102, 109-10 (2d Cir.1999) (listing several factors to be considered in determining whether error was harmless).
(1) the overall strength of the prosecution’s case;
(2) the prosecutor’s conduct with respect to the improperly admitted evidence;
(3) the importance of the wrongly admitted testimony; and
(4) whether such evidence, was cumulative of other properly admitted evidence.
(1) The Prosecution’s Case Was Weak
Cohen’s Testimony: Aaron Cohen, an illegal cab driver, testified that he rented a motel room at the Golden Gate Inn in Brooklyn for Zappulla and Jennifer under the name “Steve Greenberg.” Cohen stated that he and Jennifer were close friends, and that he spent the earlier part of that day with her smoking crack. He testified that, on the evening that he obtained the room for Zappulla, Zappulla and Jennifer entered the motel through the side door so that they would not be noticed by the motel staff. He testified that he joined the couple at various times in the motel room to smoke crack. Cohen testified that he later went by the room and, while Jennifer was sleeping, Zappulla gave him some jewelry to sell and asked him to buy crack with the proceeds. After Cohen returned with the drugs, Zappulla asked him to use the remaining proceeds to pay for the room for another day. Later that day, Cohen called the motel room and spoke with Zappulla. When Cohen asked for Jennifer, Zappulla told him that they had fought and she had left.
Cohen’s testimony was contradicted by other testimony and evidence at trial. Most importantly, although he testified that Zappulla had voluntarily given him the jewelry to sell for more crack, both Zappulla’s confession and the testimony of another inmate (see infra Op. at 466) indicated that Jennifer stole the jewelry from Zappulla. Cohen’s unsavory character was another basis to discredit his testimo*469ny. He admitted to being a crack user who ran an illegal taxi service and the desk clerk testified that Cohen regularly patronized the motel, sometimes with prostitutes and oftentimes using a pseudonym. Finally, as more fully discussed below, Cohen was potentially the other murder suspect because he was with Jennifer and Zappulla around the time of her death and had access to the motel room. Thus, Cohen’s testimony against Zappulla at trial was unreliable.
Motel surveillance tapes: These tapes merely establish the undisputed fact that Zappulla stayed at the motel with Jennifer. Two surveillance cameras were located behind the front desk, and one was outside above the main entrance. None of them was hidden, and the one above the door was readily visible. The tapes indicate that Zappulla left the motel through the front door at 11:12 p.m. and then left through the front door again at 12:18 a.m.meaning, during this hour, he had returned to the motel through the unmonitored side entrance. Between 11:56 and 12:11 a.m., motel records reveal that several telephone calls were made from Zappul-la’s motel room to various escort services. At 12:19 a.m., Zappulla returned through the front door of the motel and momentarily spoke with the motel’s desk clerk. At 12:20 a.m., Zappulla was arrested in the hallway of the motel.2 Based on this time line, Zappulla’s murder of Jennifer must have occurred prior to 11:00 p.m. However, it seems odd that, after brutally murdering Jennifer in the heat of an argument, Zap-pulla would leave through the front door of the motel, knowing that the side door was an unmonitored exit (an exit that he had used in the past when he did not want to be detected), return to the motel room through the side door, call several escort services while inside the room with Jennifer’s dead body, go back through the lobby and exit through the front door, and briefly converse with the front desk clerk. According to this time line, it is feasible that Zappulla acted this way because he was unaware that a murder had occurred in the motel room and that Jennifer’s dead body had been hidden under one of the beds.
Forensic Evidence: When police discovered Jennifer’s body underneath one of the motel beds, underwear was tied around her neck and a bloodstained towel was under the mattress. No attempt was made to test these items for any sort of forensic evidence. A pathologist testified that Jennifer died of strangulation and that she bled from her mouth and nose at the time of her death. The pathologist also testified that there were various cuts on her body in different stages of healing and there were wounds on her wrists from using needles. Although a DNA expert testified that the blood stains on Zappulla’s boots, sweatshirt, and jacket were from Jennifer, it was not proved that her blood on Zappulla was from her final injury. If Jennifer had already been murdered and hidden under one of the beds when Zap-*470pulla returned to the motel room (for example, to make telephone calls to escort services), a certain - amount of her blood may have gotten on his clothes and boots without him realizing it. Indeed, there is no evidence in the record on appeal indicating the actual amount of blood found on Zappulla’s clothing: whether it was innocuous, trace amounts of blood or whether the amount of blood on his clothing was substantial.
Pabon’s Testimony: Felix Pabon was a fellow inmate who testified that, while he and Zappulla were incarcerated together, Zappulla told him that the incident involved a prostitute, where “some guys and some girls” all went to the motel room to get high on a considerable amount of 'illegal substances. Trial Tr. at 574-75. Zap-pulla allegedly told Pabon that he fell asleep and, when he awoke, he was missing some jewelry. He blamed the prostitute for taking the jewelry, physically abused her, choked her and some blood came out and got on the wall. He said he then broke her back and placed her under the mattress.
Pabon’s testimony, however, was far from credible.3 Most importantly, he admitted that he first learned about this case from an inmate law clerk who was preparing Zappulla’s legal paperwork and that he had read some of these papers.4 Thus, there was another way for Pabon to have learned the details of Zappulla’s case other than from a confession from Zappulla. Pa-bon was also testifying pursuant to a cooperation agreement with the Bronx District Attorney. In exchange for his testimony, Pabon would receive a maximum sentence of sixteen years in a medium security facility for a cocaine related offense, to run concurrently with a sentence in a Manhattan case. He was initially facing a sentence of 25 years to life in the Bronx case, and potentially 50 years to life in the Manhattan case, in which he was charged with the attempted murder of two individuals, thereby resulting in a total exposure of 75 years imprisonment. Thus, it goes without saying that the cooperation agreement offered to Pabon in exchange for his testimony was generous.
Pabon’s credibility was significantly eroded by his extensive criminal record, which included the robbery of his brother’s girlfriend, the knife-point robbery of his landlady, -the possession of heroin with intent to sell, and the possession of an automatic weapon. He admitted to having a crack habit for approximately four to six years, and a heroin habit for another four to six years. He admitted that he would steal, lie, and rob people, even his own *471family, in order to obtain money to purchase crack, and in fact, he continued to use and sell drugs while in prison. Finally, the reliability of Pabon’s testimony is undermined by the fact that his testimony conflicted in several ways with testimony by other witnesses. Although he testified that Zappulla told him that Jennifer had stolen the jewelry, Cohen testified that Zappulla voluntarily asked him to sell the jewelry. Moreover, although Pabon testified that Zappulla told him that he “broke [Jennifer’s] back,” Trial Tr. at 575, the pathologist testified that her back had not been broken. Although Pabon testified that the incident involved “some guys and some girls,” Trial Tr. at 574, there was no evidence that anyone other than Zappulla, Cohen and Jennifer participated in the crack binge.
Other Circumstances Indicating That The Prosecution’s Case Was Weak: The Appellate Division and district court both ignored the fact that the first trial resulted in a hung jury. This event suggests that the case was close. The fact that the first jury deliberated for three days and ultimately could not reach a verdict indicates that the evidence was not so overwhelming that the outcome of trial was preordained. Cf. Kyles v. Whitley, 514 U.S. 419, 454, 115 S.Ct. 1555, 131 L.Ed.2d 490 (1995) (“This is not the ‘massive’ case envisioned by the dissent ... it is a significantly weaker case than the one heard by the first jury, which could not even reach a verdict.”); United States v. Ince, 21 F.3d 576, 585 (4th Cir.1994) (“Had the case against him been as strong as the Government would have us believe, it seems unlikely that the first jury would have ended in deadlock.”); Boyette v. Lefevre, 246 F.3d 76, 92 (2d. Cir.2001) (holding that prosecution’s failure to disclose Brady materials was not harmless error because the case against defendant was a close one, as shown in part by the fact that the first jury deadlocked).
The length and deliberative conduct by the jury at the second trial likewise suggests that a conviction was not assured, at least without the confession. See, e.g., United States v. Jean-Baptiste, 166 F.3d 102, 109-10 (2d Cir.1999) (finding plain error where jury deliberated for a day where factual issues were not complex); United States v. Quiroz, 13 F.3d 505, 513 (2d Cir.1993) (Miranda reversal where a guilty verdict resulted after three days of deliberations and Allen charge) (rehr’g granted in part on other grounds, denied in part, 22 F.3d 489 (2d Cir.1994)). Here, the jury deliberated for a full day in a straightforward single-count case, notwithstanding the extremely damaging nature of the confession. Specifically, at 11:15 a.m., the jury sought to examine the “key,” “belt,” and “underwear.” At 12:20 p.m., the jury sought to examine the “signed statement,” the “picture of body in frame,” and the “picture of blood on wall.” At 1:20 p.m., the jury sought to examine “all pictures.” At 2:10 p.m., the jury sought to hear read-backs of testimony regarding “Blood-Palumbo,” “Key-Officer recovering Key,” and “Mr. Hahn.” Finally, at 5:15 p.m., the jury reached a verdict.
(2) The Prosecutor’s Conduct With Respect To The Confession
Another relevant consideration is whether the prosecutor found the erroneously admitted evidence to be important. See Fulminante, 499 U.S. at 297-98, 111 S.Ct. 1246 (noting that the prosecution emphasized the erroneously admitted confession in its opening and closing statement); Satterwhite, 486 U.S. at 260, 108 S.Ct. 1792 (finding that the prosecution emphasized the erroneously admitted testimony at the sentencing hearing). As a general matter, the prosecution knows intimately the strengths and weaknesses of its case. This observation is animated by Ghent v. *472Woodford, where the Ninth Circuit, in a similar case, was especially persuaded by the fact that the prosecutor recognized the importance of the wrongfully admitted testimony.- 279 F-.3d 1121 (9th Cir.2002). In finding that admission of such testimony was not harmless error, the Ninth Circuit noted that “the fact that the State reordered its proof in the special circumstances [of a] retrial so as to make [the witness that provided the improper testimony] its second witness in its case-in-chief... reflects the State’s firmly held belief that [this witness’s] testimony was critical to proving [its case].” Id. at 1131.
In this case, although the witnesses and evidence at the first trial were essentially the same, the prosecution shifted its emphasis on and use of Zappulla’s confession. At the first trial, the prosecutor’s opening statement only referred to Zappulla’s confession briefly whereas at the second trial, the prosecutor heavily emphasized Zappul-la’s confession, mentioning it as the first piece of evidence against him. Indeed, the prosecutor spent a page and a half of her eight-page opening statement detailing the confession. During her summation, the prosecutor again discussed the confession in detail, for example, by explaining how the confession tied in with other evidence in the case and how the confession was credible. Further, the prosecutor emphasized at summation that the confession provided vital evidence on the crucial issue of the motive. Indeed, to discount the suggestion that Cohen may have killed Jennifer, the prosecutor emphasized that it was Zappulla and not Cohen who signed the confession.
Significantly, the prosecutor used the confession extensively even though there was a strong likelihood that the confession would be found to have been improperly admitted on appellate review. As acknowledged by the Appellate Division, there were no New York cases that found that a' 24-hour interval between the giving of Miranda warnings and a subsequent interrogation was constitutionally permissible. People, 282 A.D.2d at 697-98, 724 N.Y.S.2d 433. The fact that the prosecutor relied on the confession, thereby running the risk of reversal on appeal, tends to show that the prosecutor understood after the first trial that the confession was a" crucial piece of evidence.
(3) The Confession Was Evidence That Was Not Cumulative And Went To An Issue Central To The Case
In making a determination of harmless error, the court should also consider the importance of the improperly admitted evidence. See Satterwhite, 486 U.S. at 260, 108 S.Ct. 1792 (noting that the erroneously admitted evidence was the only evidence that established the crucial issue at sentencing regarding future rehabilitation); Fulminante, 499 U.S. at 299, 111 S.Ct. 1246 (noting that the erroneously admitted “confession was not merely cumulative” of the other evidence at trial). In this case, the confession filled in a missing link to the prosecution’s case: motive. The prosecutor acknowledged this at a hearing during trial by stating: “how do we show any motive of why the killing happened, other than by the defendant’s own statement?” During summation, the prosecutor reiterated the fact that the confession established a motive for the killing. Although respondents argue that “proof of motive is not necessary to the prosecution’s case or the jury’s verdict,” Gov’t Br. at- 54, this assertion is belied by numerous cases that hold that motive is often a central issue in murder cases. See, e.g., United States ex rel. Vanderhorst v. Lavallee, 417 F.2d 411, 414 (2d Cir.1969) (en banc) (indicating that establishing motive is central to a murder conviction); People v. Bierenbaum, 301 A.D.2d 119, 150, 748 *473N.Y.S.2d 563 (1st Dept.2002) (“There is little or nothing by way of circumstantial evidence that is more relevant or more probative [than evidence of motivation and intent] in a circumstantial murder case.”). In this case, Cohen’s testimony contradicted Pabon’s testimony regarding whether Zappulla was angry at Jennifer for allegedly stealing the jewelry and giving it to Cohen to purchase more crack. According to Cohen, Zappulla voluntarily gave him the jewelry. Thus, Zappulla’s confession resolved the apparent conflict between Cohen’s and Pabon’s testimony by making clear that Jennifer stole the jewelry and that this was why Zappulla was angry with Jennifer and why he ultimately killed her. Cf Boyette, 246 F.3d at 93 (finding that improperly withheld Blakely materials was prejudicial error because it undermined the victim’s credibility, which was a central issue at trial).
Proof of motive was especially important in this case because defense counsel suggested that Cohen was actually the murderer, and the prosecution strongly argued that Cohen could not be the killer. Zap-pulla’s defense was not far-fetched. Cohen, a habitual crack user, was “very, very close friends” with Jennifer. He was therefore more likely to kill her than a random stranger, like Zappulla. Indeed, Cohen even admitted to having an argument with Jennifer prior to her death. He was familiar with the motel, originally rented the motel room for Zappulla, and thus, he could easily have had access to the motel room. Notably, any doubt regarding the identity of the killer could have been relieved had the prosecutor ordered forensic tests on the two articles that the killer clearly touched — the underwear found around Jennifer’s neck and the blood-stained towel found under the bed. The prosecution, however, failed to do this. Moreover, there is no evidence in the record indicating whether the police also tested whether Cohen had traces of Jennifer’s blood on his clothing. Thus, the only piece of evidence at trial that unequivocally and indisputably established that Zappulla was the murderer and not Cohen was Zappul-la’s own admission of guilt.
(k) The Nature Of The Confession
The persuasive influence of a signed confession cannot be underestimated. As noted by the Supreme Court in Arizona v. Fulminante:
A confession is like no other evidence. Indeed, “the defendant’s own confession is probably the most probative and damaging evidence that can be admitted against him.... [T]he admissions of a defendant come from the actor himself, the most knowledgeable and unimpeachable source of information about his past conduct. Certainly, confessions have profound impact on the jury, so much so that we may justifiably doubt its ability to put them out of mind even if told to do so.”
499 U.S. 279, 296, 111 S.Ct. 1246, 113 L.Ed.2d 302 (1991) (quoting Bruton v. United States, 391 U.S. 123, 139—40, 88 S.Ct. 1620, 20 L.Ed.2d 476 (1968) (White, J., dissenting)). Here, the district court correctly found that, “[ujnlike any other form of evidence' — eyewitness testimony and DNA included — a confession to a crime is uniquely persuasive to a jury.” Zappulla, 296 F.Supp.2d at 318 (citing one study which found that “73 percent of jurors will vote to convict even when admissions have been repudiated by the defendant and contradicted by the physical evidence.”). The fact that the evidence at issue is a signed detailed confession should weigh heavily against finding that its erroneous admission was harmless.
* * * * * *
The district court aptly noted that an “error in admitting the confession *474should not ordinarily be deemed harmless absent a strong showing by the state that petitioner’s guilt would have been assured based solely on the other evidence presented at trial.” Id. (emphasis added). The district court, however, failed to sufficiently explain why this was not the ordinary case. To the contrary, notwithstanding the State’s retrospective assurances, this was not a “slam-dunk” prosecution where the evidence overwhelmingly weighed toward conviction. Quite the opposite, the prosecution’s theory was marred with discrepancies, inconsistencies, unreliable and conflicting testimony, shoddy forensic evidence, and logical gaps (e.g., the lack of a motive, an inconsistent time line). The importance of the confession to the case was underscored by the prosecution’s own conduct at the second trial, where it highlighted Zappulla’s confession even though the admissibility of this evidence was tenuous. In light of these considerations, we are compelled to hold that the Appellate Division’s conclusion, that the admission of Zappulla’s confession was harmless, is objectively unreasonable. Based on the overall strength of the prosecution’s case, the prosecution’s conduct with respect to the improperly admitted confession, its importance in the second trial, and the fact that a written confession can never truly be said to be merely cumulative, we cannot conclude that it was objectively reasonable for the Appellate Division to decide that the state proved “beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” See Mitchell, 540 U.S. at 17-18, 124 S.Ct. 7. Accordingly, we must reverse.
III. Zappulla’s Confession to the Police Was Obtained In Violation Of His Miranda Rights
The State argues that in the alternative this Court should find that Zappulla’s confession was not coerced. The Appellate Division and the district court both held that the confession was obtained in violation of Zappulla’s Miranda rights. This holding is undoubtedly correct. Zap-pulla was initially questioned upon arrest at the police stationhouse at 1:20 a.m. on March 17, 1998. At that time, the interrogating officers read him his Miranda rights and asked him whether he was willing to speak about the theft of his girlfriend’s fur coat and jewelry. He refused to speak about that but spoke about other matters. Late in the afternoon on March 17th, Zappulla broke free from police custody and, as he was fleeing, was struck by a car. He was recaptured and taken to the hospital for examination. Following Zappulla’s return to police custody, at 12:30 a.m. on March 18, he was again questioned, but this time without a statement of his Miranda rights and about the much more serious crime of murder.
The Appellate Division found that Zap-pulla’s confession was not voluntary and should have been suppressed. People, 282 A.D.2d. at 697-98, 724 N.Y.S.2d 433. The Appellate Division relied on the fact that: (1) 24-hours had lapsed between the giving of Miranda warnings and the questioning of Zappulla about Jennifer’s murder; (2) Zappulla was not in continuous police custody between the initial giving of Miranda warnings and the subsequent interrogation; and (3) the second interrogation concerned a crime unrelated to that for which he was initially arrested. On habeas review, the district court properly adopted these finding in affirming the Appellate Division’s decision. Zappulla, 296 F.Supp.2d at 318.
Considering the “totality of the circumstances,” Fulminante, 499 U.S. at 286, 111 S.Ct. 1246, we conclude that the admission of Zappulla’s confession constitutes a violation of Zappulla’s due process rights. See Miranda, 384 U.S. at 444, 86 S.Ct. 1602. *475Accordingly, we reject the State’s alternative argument on appeal.
In conclusion, as Judge Richard S. Arnold reminded us:
A system of law that not only makes certain conduct criminal, but also lays down the rules for the conduct of authorities, often becomes complex in its application to individual cases, and will from time to time produce imperfect results, especially if one’s attention is confined to the particular case at bar. Some criminals do go free because of the necessity of keeping government and its servants in their place. That is one of the costs of having and enforcing a Bill of Rights. This country is built on the assumption that the cost is worth paying, and that in the long run we are all both freer and safer if the Constitution is strictly enforced.
Williams v. Nix, 700 F.2d 1164, 1173 (8th Cir.1983). With Zappulla’s unconstitutionally obtained confession in mind, it may not be too difficult to look at other evidence and conclude that Zappulla would have been convicted in any event. The unlawfully obtained confession, however, was far and away the most convincing evidence of his guilt. See Fulminante, 499 U.S. at 296, 111 S.Ct. 1246. We conclude that it was “objectively unreasonable” for the Appellate Division to decide “beyond a reasonable doubt that [the trial court’s wrongful introduction of the unlawfully obtained confession into evidence] did not contribute to the verdict obtained.” Mitchell, 540 U.S. at 17-18, 124 S.Ct. 7 (emphasis added). We do not think it too much to require the State to return to the trial court and attempt to convict Zappulla without the unconstitutionally obtained confession. If the dissent’s analysis is right, by following it, the State should not find it difficult to properly obtain a conviction. Requiring the State to try is one of the costs of having and enforcing a Bill of Rights.
CONCLUSION
For the reasons stated above, we hereby REVERSE the district court’s denial of a writ of habeas corpus, VACATE Zappul-la’s state conviction for murder, and REMAND to the district court with instructions to grant the petition for a writ of habeas corpus unless the State grants a new trial within a reasonable period.
. As acknowledged in Brown, although numerous cases in this circuit have previously observed that the standard for reviewing a harmless error determination remains uncertain, all of these cases have declined to directly confront this issue, finding instead that "the result was the same under either test.” 355 F.3d at 91 (citing cases).
. The Time Line:
9:00 p.m.-ll:00 p.m. Jennifer is murdered. Zappulla is in the motel room.
11:12 p.m. Zappulla exits the motel through the front door.
[At one point he returns to the motel through the side door]
11:56 p.m.-12:ll a.m. Several calls to escort services from Zappul-la’s motel room.
Zappulla exits through the front door of the motel again. 12:18 a.m.
Zappulla enters though the front door and speaks to the desk clerk. 12:19 a.m.
Zappulla is arrested in the motel hallway. 12:20 a.m.
. As a general matter, we note that numerous scholars and criminal justice experts have found the testimony by “jail house snitches” to be highly unreliable. See Daryl K. Brown, Essay, Rationing Criminal Defense Entitlements: An Argument From Institutional Design, 104 COLUM. L. REV. 801, 824 (2004). Several reports have found that jailhouse informants have a significant incentive to offer testimony against other defendants in order to curry favor with prosecutors and that the proffered testimony is oftentimes partially or completely fabricated. Thus, “the use of jailhouse informants to obtain convictions may be ‘one of the most abused aspects of the criminal justice system.’ " Jana Winograde, Comment, Jailhouse Informants And The Need for Judicial Use Immunity in Habeas Corpus Proceedings, 78 CAL L. REV 755, 756 (1990); see also Comm’n on Capital Punishment, Report of the Governor’s Commission on Capital Punishment 96,120, 158 (2002), at http://www.idoc.state.il.us/ccp/ccp/reports/ commission_report/complete_report.pdf.
. Although Pabon testified that Zappulla first showed him a copy of the indictment before Pabon spoke with the inmate law clerk, upon further questioning, Pabon admitted that he had not seen the indictment but instead another piece of “paper.” Trial Tr. at 606-07.