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-In recent years, the Supreme Court has applied two different standards of review to criminal cases in which a federal constitutional right of the defendant was violated. The Court has failed, however, to announce a coherent rationale as to which violations are to be reviewed by the strict "automatic reversal" standard and which by the more lenient "harmless error" standard. This failure has deprived the lower courts of guidance for judging types of violations not yet treated by the Supreme Court.1 The selection of the standard is often decisive; under the "automatic reversal" standard proof of the violation is sufficient to require reversal, while under the "harmless error" standard the appellant must demonstrate in addition that the outcome of his case was affected by the violation.

Principles for Application of the Harmless Error Standard