Summary Of Chapman Vs California

At one time, courts applied the same test for determining whether a federal constitutional error was harmless in direct appeals and habeas corpus proceedings. Chapman v. California, 386 U.S. 18 (1967) was the standard for harmless error review in both direct appeals and habeas corpus proceedings. Currently, the applicable harmlessness standard depends on the procedural posture of the case. Chapman remains the standard for direct appeals, but the standard in a collateral proceeding differs from a direct appeal. The relevant standard followed by federal courts in collateral proceedings was announced in Brecht v. Abrahamson, 507 U.S. 619 (1993).
The transition in the standard from Chapman to Brecht is discussed in detail below.
II. THE HARMLESSNESS