determining whether habeas relief must be granted is whether the Doyle error “‘had substantial and injurious effect or influence in determining the jury’s verdict.’ ” Id. at-, 113 S.Ct. at 1722 (quoting Kotteakos v. United States, 328 U.S. 750, 66 S.Ct. 1239, 90 L.Ed. 1557 (1946)). This standard must now be followed in habeas proceedings, in lieu of the “harmless beyond a reasonable doubt” standard announced in Chapman v. California, 386 U.S. 18, 87 S.Ct. 824, 17 L.Ed.2d 705 (1967), and applied in direct appeals. Since Brecht, our court and others have held generally that the Brecht/Kotteakos standard applies in habeas proceedings where the court must decide whether a constitutional trial error requires reversal of the conviction. E.g., Kyles v. Whitley, 5 F.3d 806, 807 (5th Cir.1993) (<HOLDING>); Shaw v. Collins, 5 F.3d 128, 132 (5th
holding that instructional errors that do not categorically vitiate all the jurys findings  are trial errors as to which harmless error analysis applies not structural errors emphasis and internal quotation marks omitted quoting neder v united states 527 us 1 11 119 sct 1827 144 led2d 35 1999 holding that all sentencing errors must be preserved holding that errors in state law cannot support federal habeas relief holding that in habeas proceedings brecht standard controls all trial as distinguished from structural errors recognizing categorical approach to structural errors that presumptively satisfy the third prong of olano and listing classes of cases that present structural errors