The following excerpt is from U.S. v. Mohawk, 20 F.3d 1480 (9th Cir. 1994):
4 Harmless error analysis is inapplicable to the unconstitutional denial of the right to counsel. See Balough, 820 F.2d at 1490 (relying on Rose v. Clark, 478 U.S. 570, 577-78, 106 S.Ct. 3101, 3105-06, 92 L.Ed.2d 460 (1986)).
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