In the case of Carella v. California, 1988, the U.S Supreme Court ruled that a conviction based on jury instructions containing an erroneous conclusive presumption is not harmless error simply because other evidence supporting guilt was overwhelming. The defendant, Joseph Carella, had been convicted for grand theft auto under two statutes in California law which contained presumptions regarding possession of recently stolen property and altered vehicle identification numbers (VINs). However, these presumptions were deemed unconstitutional as they removed from the jury's consideration elements necessary to prove guilt beyond reasonable doubt. Despite strong circumstantial evidence against Carella including his fingerprints found on one of the stolen vehicles and false statements made to police officers about how he obtained them; it was held that such errors are not subject to harmless-error analysis since they vitiate all factual findings by juries or judges.

In the dissenting opinion for Carella v. California, Justice Scalia argued that while the jury instructions were indeed flawed, they did not necessarily warrant a reversal of conviction. He contended that there was no reasonable doubt about whether or not the defendant had committed theft since he knowingly possessed stolen property and intended to keep it away from its rightful owner. Therefore, even though the jury instruction erroneously presumed intent from possession alone (which is unconstitutional), this error was harmless beyond a reasonable doubt in this particular case because other evidence overwhelmingly proved intent. Thus, according to Scalia's view, despite an instructional mistake by trial court regarding presumption of guilt based on mere possession of stolen goods without direct proof of criminal intent; it should not have led to automatic reversal as long as such error could be deemed harmless due to overwhelming evidence supporting same conclusion under correct legal standards.