The following excerpt is from Lambright v. Stewart, 167 F.3d 477 (9th Cir. 1999):
In United States v. Annigoni, 96 F.3d 1132, 1144 (9th Cir.1996), this court determined that the error at issue was not amenable to harmless-error analysis, and thus required automatic reversal of the conviction, but did not reach the question of whether the error was appropriately classified as structural. See id. As we stated in that case:
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