The following excerpt is from United States v. Chieppa, 241 F.2d 635 (2nd Cir. 1957):
This error was harmless because the Government's case was overwhelming and hence the "record fairly shrieks the guilt" of all the appellants. Lutwak v. United States, 1953, 344 U.S. 604, 619, 73 S.Ct. 481, 490, 97 L.Ed. 593. As in Lutwak, "we have found only one instance where a declaration made after the conspiracy had ended was admitted against all of the alleged conspirators, even though not present when the declaration was made," and therefore "we cannot conceive how this one admission could have possibly influenced this jury to reach an improper verdict." Ibid.
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