The following excerpt is from U.S. v. Lee, 942 F.2d 794 (9th Cir. 1991):
The admission of hearsay may violate the rights guaranteed under the confrontation clause of the sixth amendment. See United States v. Magana-Olvera, 917 F.2d 401, 409 (9th Cir.1990). Nevertheless, "[c]onfrontation clause violations are subject to harmless error analysis. Reversal is not required if 'the error was harmless beyond a reasonable doubt.' " Id.
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