the statements we got to partying a little bit and things got out of hand. My roommate killed one and I killed the other. I killed Kevin. You would have heard the exact same statements. The ost-Miranda silence violates the Due Process Clause. See Doyle v. Ohio, 426 U.S. 610, 619, 96 S.Ct. 2240, 49 L.Ed.2d 91 (1976) (‘We hold that the use for impeachment purposes of petitioners’ silence, at the time of arrest and after receiving Miranda warnings, violated the Due Process Clause of the Fourteenth Amendment.”). The Supreme Court, however, concluded that Griffin error did not mandate automatic reversal if it was harmless. Chapman v. California, 386 U.S. 18, 22, 87 S.Ct. 824, 17 L.Ed.2d 705 (1967); see also United States v. Hasting, 461 U.S. 499, 509, 103 S.Ct. 1974, 76 L.Ed.2d 96 (1983) (<HOLDING>). In Brecht, the Supreme Court held that Doyle
holding that chapman harmless error analysis is stricter than its rule 52a counterpart holding that chapman mandates harmless error analysis of griffin error holding that any error was harmless and thus not plain error recognizing that where the error involved defies analysis by harmless error standards or the data is insufficient to conduct a meaningful harmless error analysis then the error will not be proven harmless beyond a reasonable doubt holding that chapman harmless error review will be conducted when error is tested for harmlessness for the first time on habeas