The following excerpt is from Lemmon v. Fraunheim, No. 2:17-cv-1639 KJM KJN (E.D. Cal. 2019):
The jury's finding establishes it would not have found him guilty of a lesser crime than Freed or somehow less culpable than Freed because it considered him a major participant. See O'Neal v. McAninch, 513 U.S. at 434 (habeas relief is available only if the record demonstrates the jury's decision was substantially influenced by an error or there is "grave doubt" about whether an error was harmless).
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