carried "during and in relation to” a drug trafficking offense. Cf. infra Part II.B (noting that defendant does contest the "during and in relation to” element with respect to his claim of instructional error). More than thirty packets of crack cocaine were found in Johnson's clothes, which were lying beside him on the bed. A reasonable jury could readily have concluded that the drugs had been on Johnson’s person when he pointed the gun at Officer Flynn, and/or that he had both the gun and drugs with him as he fled down the air shaft. 4 . Chapman sets the standard for determining, on direct appeal, whether constitutional error was harmless. Kotteakos v. United States sets the standard for measuring nonconstitutional harmless error. 328 U.S. 750, 776, 66 S.Ct. 1239, 90 L.Ed. 1557 (1946) (<HOLDING>). In Brecht v. Abrahamson, the Supreme Court
holding that a substantial right is affected when the error had a substantial and injurious effect or influence in determining the jurys verdict holding that nonconstitutional error is harmless if it did not have substantial and injurious effect or influence in determining the jurys verdict holding that an error must have a substantial and injurious effect on the verdict to entitle a petitioner to habeas relief holding that the states improper use of the defendants postmiranda silence to impeach the defendants claim that shooting was accidental did not have substantial and injurious effect or influence in determining jurys verdict and thus was harmless error holding that states improper use of defendants postmiranda silence was error but did not warrant habeas relief unless error had a substantial and injurious effect or influence on the jurys verdict