Where hearsay, consisting of an inculpatory, out-of-court statement made other than to law enforcement, is erroneously introduced to the defendant's prejudice in a criminal trial, should appellate review for harmlessness track the same standard applicable under Delaware v. Van Arsdall, 475 U.S. 673 (1986), for review of an equivalent violation of the Confrontation Clause, given the indistinguishable impact on the defendant's cross-examination and other trial rights?

Where hearsay, consisting of an inculpatory, out-of-court statement made other than to law enforcement, is erroneously introduced to the defendant's prejudice in a criminal trial, should appellate review for harmlessness track the same standard applicable under Delaware v. Van Arsdall, 475 U.S. 673 (1986), for review of an equivalent violation of the Confrontation Clause, given the indistinguishable impact on the defendant's cross-examination and other trial rights?