substantially duplicated any incriminating inference that jurors might have drawn from Clinton’s statements. For instance, the government introduced phone records showing that Clinton had placed a 22-second phone call to Nadine just as the courier was leaving the tax office on the day of the robbery, as well as recordings of Nadine describing to Varvaro the manner by which Clinton would alert her of the impending delivery of tax sale proceeds. See Rubio, 709 F.2d at 155 (noting that co-defendant’s contested statement presented "nothing new or incriminating ... which had not already been presented” through other evidence). Thus, even if the District Court had erred under Bruton, the error was harmless. See Delaware v. Van Arsdall, 475 U.S. 673, 684, 106 S.Ct. 1431, 89 L.Ed.2d 674 (1986)
holding trial errors are subject to a harmless error analysis holding blakely errors are subject to harmless error analysis holding confrontation clause violations subject to harmless error analysis holding that instructional errors that are trial errors are subject to harmless error analysis holding that confronta tion clause errors were subject to harmless error analysis