In the case of Harris, Superintendent, Green Haven Correctional Facility v. Rivera (1981), the United States Supreme Court ruled in favor of a prison superintendent who had been sued by an inmate for allegedly violating his constitutional rights during trial. The inmate, Sixto Rivera, claimed that he was denied due process because the jury instructions given at his trial were constitutionally inadequate and led to him being unfairly convicted. However, the Supreme Court disagreed with this argument on appeal from lower courts' decisions. The court held that even if there was error in jury instruction it did not automatically violate due process unless it can be established that such error caused actual prejudice or harm to defendant's case which could have influenced outcome of verdict. In this particular instance, they found no evidence suggesting any substantial likelihood of misguidance from potentially erroneous instructions hence concluded no violation occurred.

In the dissenting opinion for Harris v. Rivera, Justice William Rehnquist argued that the majority's decision to uphold a lower court ruling was incorrect because it failed to consider whether there had been any actual constitutional violation in the case. He contended that even if there were errors made during jury deliberations, these did not necessarily equate to a breach of constitutional rights. Furthermore, he disagreed with the majority's interpretation of Chapman v. California and its application in this case; according to him, harmless error analysis should only be applied when an error has occurred but does not affect substantial rights or result in manifest injustice - which he believed was not proven here. He also criticized their reliance on speculation about what might have happened during jury deliberation rather than concrete evidence.