U.S. at 695-96, 122 S.Ct. 1843 (footnote and citations omitted). The Bell Court specifically cited Brooks as an example. Id. at 696 n. 3, 122 S.Ct. 1843. Petitioner brought a valid Brooks claim. According to Cronic and its progeny, Brooks violations are structural errors, which require the presumption of prejudice and automatic reversal. For this reason, the magistrate judge erred in. applying a harmless error analysis, and this Court concludes that Petitioner’s claim requires automatic reversal. See, e.g., Frost v. Van Boening, 757 F.3d 910, No. 11-35114, 2014 WL 1677820 (9th Cir. Apr. 29, 2014) (reversing denial of habeas petition where Washington Supreme Court found a structural error, but then applied harmless error analysis); Musladin v. Lamarque, 555 F.3d 830, 838 (9th Cir.2009) (<HOLDING>). Even if harmless error analysis applies, the
holding that posttrial motion for new trial is critical stage requiring counsel or valid waiver holding cronics rule requiring automatic reversal where a defendant was denied counsel at a critical stage is binding on this court and applies in proceedings governed by aedpa footnote omitted holding that sentencing is a critical stage of criminal proceedings and the offer of counsel must be renewed at each critical stage where the defendant appears without counsel holding that the filing of a motion for a new trial is a critical stage of the prosecution and that an indigent defendant is constitutionally entitled to the assistance of counsel at that stage holding that the right to counsel applies in all critical stages of state and federal criminal proceedings