People v. Anderson

In People v. Anderson (After Remand), 446 Mich 392, 405; 521 NW2d 538 (1994), the Supreme Court of Michigan indicated that certain "structural" constitutional errors are not subject to harmless error review. The Anderson Court listed "the total deprivation of the right to trial counsel" as one of these errors. Id. The Anderson Court went on to indicate that "trial errors" occurring during the presentation of the case to the jury are subject to harmless-error review, because they "'may . . . be quantitatively assessed in the context of other evidence presented in order to determine whether the error was harmless beyond a reasonable doubt.'" Id. at 405-406.