and ownership of a mischievous animal causing death. She challenges the district court’s denial of her federal habeas petition. We agree with the district court that the California Court of Appeal did not unreasonably apply clearly established federal law when it determined that a limitation on defense counsel’s ability to make objections during the end of the Government’s closing rebuttal argument did not rise to the level of structural error. See United States v. Cronic, 466 U.S. 648, 659, 104 S.Ct. 2039, 80 L.Ed.2d 657 (1984) (explaining that structural error occurs only when there is a complete deprivation of counsel). Note 25 of the Cronic opinion does not override the clear holding of the case as a whole. See Glebe v. Frost, — U.S. -, 135 S.Ct. 429, 431, 190 L.Ed.2d 317 (2014) (<HOLDING>) (emphases in the original). The California
holding that where counsels deficient performance resulted in structural error prejudice will be presumed holding that a defendant who is seeking to excuse a procedurally defaulted claim of structural error need not establish actual prejudice holding that the omission of an element is not a structural error subject to automatic reversal but rather  where objected to  is subject to harmless error analysis holding that complete denial of summation amounts to structural error and that existing case law did not clearly establish the restriction of summation as structural error holding error was structural because of the difficulty of assessing the effect of the error