438
Opinion of the Court
conclude that substantial rights were not affected. The inquiry cannot be merely whether there was enough to support the result, apart from the phase affected by the error. It is rather, even so, whether the error itself had substantial influence. If so, or if one is left in grave doubt, the conviction cannot stand." 328 U. S., at 764- 765 (emphasis added).
Id., at 776 (holding that error is not harmless if it had "substantial and injurious effect or influence" upon the jury). That is to say, if a judge has "grave doubt" about whether an error affected a jury in this way, the judge must treat the error as if it did so. See also United States v. Olano, 507 U. S. 725, 741 (1993) (stating that under Federal Rule of Criminal Procedure 52(a) the Government bears the "burden of showing the absence of prejudice"); United States v. Lane, 474 U. S. 438, 449 (1986) (quoting Kotteakos as providing the proper harmless-error standard in cases of misjoinder and quoting " 'grave doubt' " language).
When this Court considered the same question in the context of direct review of a constitutional trial error, it applied the same rule. See Chapman, 386 U. S., at 24 (holding that error is harmless only if "harmless beyond a reasonable doubt"). Indeed, the Chapman Court wrote that "constitutional error . . . casts on someone other than the person prejudiced by it a burden to show that it was harmless." Ibid.
We must concede that in Brecht v. Abrahamson this Court, in the course of holding that the more lenient Kotteakos harmless-error standard, rather than the stricter Chapman standard, normally governs cases of habeas review of constitutional trial errors, stated that habeas petitioners "are not entitled to habeas relief based on trial error unless they can establish that it resulted in 'actual prejudice.' " Brecht, 507 U. S., at 637 (emphasis added). This language, however, is not determinative. The issue in Brecht involved a choice of substantive harmless-error standards: the stricter Chapman, or the less strict Kotteakos,
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