In the case of Arizona v. Fulminante, the U.S. Supreme Court ruled in 1991 that a coerced confession can be classified as a "harmless error" and does not automatically require reversal of conviction if there is overwhelming evidence pointing to guilt beyond reasonable doubt. The defendant, Oreste Fulminante, was convicted for murdering his stepdaughter based on two confessions he made while in prison - one to an undercover FBI agent posing as a fellow inmate and another to his then-wife after being released from jail. His lawyers argued that these confessions were obtained under duress and should have been excluded from trial proceedings; however, the court held by majority decision (5-4) that even though the first confession was indeed coerced and thus violated Fifth Amendment rights against self-incrimination, it did not necessarily invalidate Fulminante's conviction because other substantial evidence supported his guilt.

In the dissenting opinion for Arizona v. Fulminante, Justice White argued that the majority's decision to categorize a coerced confession as a "trial error" rather than a "structural defect" was incorrect and without precedent. He contended that such an approach undermined the importance of protecting defendants from coercive interrogations, which he believed was central to ensuring fair trials. Furthermore, he disagreed with the majority's assertion that harmless-error analysis could apply in this case because it assumed juries would not be influenced by confessions obtained through coercion. He also criticized their reliance on hypothetical scenarios instead of focusing on actual trial proceedings when determining whether or not an error had occurred.