interchangeably); United States v. McMutuary, 217 F.3d 477, 481-82 (7th Cir.2000) (“A defendant’s burden to show actual and substantial prejudice is an exacting one; the show must rest upon more than mere speculative harm”); United States v. Edwards, 159 F.3d 1117, 1128 (8th Cir.1998) (“actually, substantially prejudiced”); United States v. Doe, 149 F.3d 945, 948 (9th Cir.1998) (“actual, non-speculative prejudice”); United States v. Wood, 207 F.3d 1222, 1235 (10th Cir.2000) (“actual” prejudice); United States v. Foxman, 87 F.3d 1220, 1223 (11th Cir.1996) (“actual substantial” prejudice). It appears that only one Circuit specifically approaches the question in a dual fashion, requiring proof of both actual and substantial prejudice. See Jones v. Angelone, 94 F.3d 900, 907 (4th Cir.1996) (<HOLDING>). The U.S. Supreme Court has not directly
holding that a defendant must show actual prejudice to succeed on an ineffective assistance of counsel claim holding that an assertion of prejudice is not a showing of prejudice holding that a defendant must not only show actual prejudice as opposed to mere speculative prejudice  but also  any actual prejudice was substantial  that he was meaningfully impaired in his ability to defend against the states charges to such an extent that the disposition of the criminal proceeding was likely affected holding that if delay in the prosecution of disciplinary charges substantially impaired the attorneys ability to defend against the charges  the constitution might compel a different analysis a delay coupled with actual prejudice could result in a due process violation  holding that there was no actual prejudice where the defendant has the functional equivalent of the notice required