Cite as: 507 U. S. 619 (1993)
Opinion of the Court
events at any time before trial, see n. 2, supra, crossed the Doyle line. For it is conceivable that, once petitioner had been given his Miranda warnings, he decided to stand on his right to remain silent because he believed his silence would not be used against him at trial.
The Court of Appeals characterized Doyle as "a prophylactic rule." 944 F. 2d, at 1370. It reasoned that, since the need for Doyle stems from the implicit assurance that flows from Miranda warnings, and "the warnings required by Miranda are not themselves part of the Constitution," "Doyle is . . . a prophylactic rule designed to protect another prophylactic rule from erosion or misuse." Ibid. But Doyle was not simply a further extension of the Miranda prophylactic rule. Rather, as we have discussed, it is rooted in fundamental fairness and due process concerns. However real these concerns, Doyle does not " 'overprotec[t]' " them. Duckworth v. Eagan, 492 U. S. 195, 209 (1989) (O'Connor, J., concurring). Under the rationale of Doyle, due process is violated whenever the prosecution uses for impeachment purposes a defendant's post-Miranda silence. Doyle thus does not bear the hallmarks of a prophylactic rule.
Instead, we think Doyle error fits squarely into the category of constitutional violations which we have characterized as " 'trial error.' " See Arizona v. Fulminante, 499 U. S. 279, 307 (1991). Trial error "occur[s] during the presentation of the case to the jury," and is amenable to harmless-error analysis because it "may . . . be quantitatively assessed in the context of other evidence presented in order to determine [the effect it had on the trial]." Id., at 307-308. At the other end of the spectrum of constitutional errors lie "structural defects in the constitution of the trial mechanism, which defy analysis by 'harmless-error' standards." Id., at 309. The existence of such defects—deprivation of the right to counsel,4 for example—requires automatic reversal of the
4 Gideon v. Wainwright, 372 U. S. 335 (1963).
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