What is the burden of proving that a constitutional error or procedural error contributed to a sentence imposed by a plea?

Even constitutional errors are reviewed for actual prejudice² to the petitioner (usually by requiring that petitioners establish the existence of meritorious claims). Generally, this means that petitioner must prove, or at least allege, that the outcome would have been different had the error not occurred. See, e.g., Morales v. United States, 143 F.3d 94, 96 (2d Cir. 1998) (holding that prejudice resulting from deficient representation is determined by many circumstances, including

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"the variable merits and prospects on appeal, especially one from a sentence imposed by a plea."); see also Brecht v. Abrahamson, 507 U.S. 619, 622 (1993) (reviewing government's unconstitutional use of petitioner's post-Miranda silence for a substantial and injurious effect on the jury's verdict). I cannot imagine that we would place a higher burden on a petitioner raising an undisputed constitutional error, than on a petitioner raising clearly non-constitutional violations of federal statutes and of procedural rules. When the petitioner raises a mere procedural claim, therefore, we should not be hard-pressed to give him a voice when others with weightier claims are not entitled to one.