Does the harmless error doctrine apply on appeal from a guilty plea entered following a denial of a motion to suppress evidence?
California, United States of America
The following excerpt is from People v. Swearingen, 148 Cal.Rptr. 755, 84 Cal.App.3d 570 (Cal. App. 1978):
Here but for People v. Hill (1974) 12 Cal.3d 731, 117 Cal.Rptr. 393, 528 P.2d 1 (which holds that the harmless error doctrine is inapplicable on appeal from a guilty plea entered following erroneous denial of a motion to suppress evidence (Pen. Code, 1538.5, subd. (m)), the judgment should clearly be affirmed under the harmless error doctrine.
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