point, its admonition that "to obtain collateral relief a prisoner must clear a significantly higher hurdle than would exist on direct appeal under the plain error standard," Frady, 456 U.S. at 166, indicates that a prisoner must, at a minimum, satisfy all of the requirements of the plain error standard in order to succeed in a collateral attack. 14 . In Cotton itself, drug quantity was omitted from the jury instructions as well as from the indictment, although the Court did not discuss the relevance of the former omission. See Cotton, 535 U.S. at 628, 122 S.Ct. 1781. In Pettigrew’s case, although the issue of drug quantity was omitted from the juiy instructions, each count of the indictment alleged the distribution of 50 grams or more of cocaine base. 15 . See Dale, 140 F.3d at 1057 (<HOLDING>) (citation omitted); cf. Neder v. United
holding that the harmlesserror rule of chapman v california  applies to the failure of a trial judge to submit an element of the offense to the jury holding that failure to submit an element of the offense to the jury is subject to harmless error analysis holding that a jury instruction directing the verdict on one element deprived defendant of the right to a jury determination on every element of the charged offense and thus constituted structural error holding omission in the jury instruction of element of offense requires a new trial holding that the cause and prejudice standard applies on collateral review when an element of an offense has been decided by a court rather than a jury and rejecting the contention that the failure to submit an element to the jury is necessarily prejudicial merely because it requires speculation about what a hypothetical jury could have decided had it been allowed to do so