The Appellate Division, Second Department, did not run afoul of established precedent when it ruled that the introduction at trial of a written statement was harmless error, a federal appeals court held on April 3.

Reversing a grant of habeas corpus to a prisoner serving a 15-year sentence for burglary, the U.S. Court of Appeals for the Second Circuit agreed with the Second Department that a written statement admitted at the trial of Carlos Evans was hearsay, but not enough to warrant overturning his conviction.