The Warren Court is celebrated for revolutionizing protection of individual liberty. While Chapman v. California might seem to stand in stark contrast with this view, a closer look reveals it is consonant with the Warren Court’s progressive jurisprudence. Chapman held that violations of constitutional rights may be subject to harmless error analysis, however it created a strict test for this analysis and shifted the burden of proof to the government, demonstrating the Court’s continued commitment to constitutional rights. Had subsequent Courts been faithful to Chapman’s construct, it might well have reduced, at least in part, the continuing problems with ineffective assistance of counsel and prosecutorial misconduct that currently mar the criminal justice system.