subject to harmless error analysis.” Franco is not entitled to a reversal of the restitution order unless she can establish that the error “had substantial and injurious effect or influence in determining” the amount of the restitution. She has not done so. A violation of the confrontation clause of the Sixth Amendment, made applicable to state trials through the Due Process clause of the Fourteenth Amendment, “does not require the setting aside of the state conviction if the evidence of guilt is so overwhelming as to make the error harmless beyond a reasonable doubt.” Applying this standard to a restitution hearing, an error is harmless if the evidence that is properly admitted leaves no room for the judge to entertain a reasonable doubt as to the proper amount of restitut h Cir.1993) (<HOLDING>) quoting United States v. Kikumura, 918 F.2d
holding that the confrontation clause does not apply to the sentencing hearing holding that constitution protected right to counsel at sentencing even where it was waived at trial holding that confrontation clause protections do not extend to sentencing hearings holding confrontation clause inapplicable at sentencing holding the confrontation clause of the united states constitution does not apply at sentencing under the us sentencing guidelines manual and the procedural protections afforded a convicted defendant at sentencing are traditionally less stringent than the protections afforded a presumptively innocent defendant at trial