United States v. Odonis Parker, 11 F.4th 593

Shots were fired at Selina Schutt and Jamayl Wash’s car; Schutt identified her recently estranged ex‑boyfriend, Odonis Parker, as the shooter in a 911 call, to police, and at trial.
Ballistics: a live round and a spent casing found near the victim car matched an SKS rifle recovered in the trunk of a Ford Fusion.
When officers detained Parker leaving a nearby building, he had the only set of keys to the Fusion; the trunk contained the rifle, a 2XL red hoodie (witnessed on the shooter), Parker’s debit card, and paperwork with his name; owner testified she had loaned the car to Parker that day.
Forensics: latent‑print examiner found no usable prints on the gun/magazine; investigators did not collect DNA from the weapon or sweatshirt and did not submit bullets for fingerprinting; defense sought to question witnesses about lack of DNA testing.
District court limited voir dire and barred cross‑examination and opening‑statement references to the absence of DNA testing (Rule 403), permitting only targeted challenges on proper foundation; Parker was convicted under 18 U.S.C. § 922(g)(1) and sentenced to 114 months.
On appeal Parker argued the district court violated his Sixth Amendment confrontation/cross‑examination rights by prohibiting inquiry into the absence of DNA testing; the Seventh Circuit assumed preservation but found any error harmless beyond a reasonable doubt and affirmed.

Issue	Parker's Argument	Government's Argument	Held
Whether the district court violated the Sixth Amendment by barring cross‑examination about the absence of DNA testing tying Parker to the gun	Excluding questions about DNA testing foreclosed meaningful confrontation and was central to his theory that forensic evidence did not tie him to the weapon	The questioning would invite speculation, lacked foundation or expert testimony, risked confusion and prejudice, and the claim may be waived	Even if exclusion were error, it was harmless beyond a reasonable doubt because eyewitness ID and robust circumstantial evidence overwhelmingly proved possession
Whether the Confrontation/objection was preserved and standard of review	Substance of the objection was raised below, so appellate review should not be for plain error only	Argued Parker failed to invoke the Confrontation Clause specifically and thus waived it	Court assumed preservation; declined to decide waiver and applied harmless‑error analysis instead

Mitchell v. Esparza, 540 U.S. 12 (2003) (constitutional errors are subject to harmless‑error analysis)
United States v. Stewart, 902 F.3d 664 (7th Cir. 2018) (harmless‑error test considers whether wrongful evidence affected average juror’s view)
United States v. Curtis, 781 F.3d 904 (7th Cir. 2015) (application of harmless‑error standard)
United States v. Shelton, 997 F.3d 749 (7th Cir. 2021) (affirming where untainted evidence of guilt was overwhelming)
United States v. Guzman‑Cordoba, 988 F.3d 391 (7th Cir. 2021) (harmless error where cumulative guilt evidence was overwhelming)
United States v. Groce, 891 F.3d 260 (7th Cir. 2018) (even erroneous limitation on cross‑examination can be harmless when evidence of guilt is overwhelming)
United States v. Martin, 618 F.3d 705 (7th Cir. 2010) (Confrontation Clause error is harmless if excluded testimony would have added little new information)