113 S.Ct. at 1714 (quoting Kotteakos v. United States, 328 U.S. 750, 776, 66 S.Ct. 1239, 1253, 90 L.Ed. 1557 (1946)). Before turning to the analytical justification for this legal conclusion, we note that, in drawing the conclusion that we have, we join three other circuits that have addressed the appropriate standard of review in evaluating a habeas petitioner’s claim that the jury improperly considered extrinsic material evidence in reaching its verdict. See Jeffries v. Wood, 114 F.3d 1484, 1489 (9th Cir.1997) (applying the Brecht harmless error standard in evaluating a habeas petitioner’s Sixth Amendment claim based on a juror’s disclosure of information regarding the petitioner’s criminal history to other members of the jury); Sherman v. Smith, 89 F.3d 1134, 1137-42 (4th Cir.1996) (<HOLDING>); Bibbins v. Dalsheim, 21 F.3d 13, 16 (2d
holding that a jurors unauthorized inspection of a tree in which the petitioner allegedly hid the murder weapon did not warrant habeas relief because it did not have a substantial and injurious effect in determining the jurys verdict 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 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