What is the effect of an alleged instructional error in the course of a criminal case?

Defendant claims that the effect of the asserted instructional error was that there never was a valid jury determination that he suffered any of the three convictions, claiming that the reasoning of the high court's decision in Sullivan v. Louisiana (1993) 508 U.S. 275 leads to the conclusion that the error is reversible per se. That decision, however, applied an automatic-reversal rule to a constitutionally deficient reasonable-doubt instruction on the issue of guilt. The

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