Prior to the mid-1990s, there was no harmless error and nearly any mistake, especially a violation of a defendant's constitutional rights, was considered serious or prejudicial even if it did not affect the outcome of the trial.

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Before the mid-1990s, the "harmless error" rule already existed, allowing appellate courts to affirm convictions if they believed beyond a reasonable doubt that errors committed during the trial did not affect the trial's outcome, even if those errors involved constitutional rights.

Prior to the Mid-1990s, There Was No Harmless Error and Nearly