The following excerpt is from Edwards v. Yest, 9 F.3d 1551 (9th Cir. 1993):
whether the error "had substantial and injurious effect or influence in determining the jury's verdict." Under this standard, habeas petitioners may obtain plenary review of their constitutional claims, but they are not entitled to habeas relief based on trial error unless they can establish that it resulted in "actual prejudice."
Brecht v. Abrahamson, --- U.S. ----, 113 S.Ct. 1170, 1722 (1993) (citations omitted).
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