What is the test for establishing prejudice resulting from a procedural default?

MultiRegion, United States of America

The following excerpt is from White v. Lewis, 874 F.2d 599 (9th Cir. 1989):

To establish prejudice resulting from a procedural default, a habeas petitioner bears "the burden of showing not merely that the errors at his trial constituted a possibility of prejudice, but that they worked to his actual and substantial disadvantage, infecting his entire trial with errors of constitutional dimension." United States v. Frady, 456 U.S. 152, 170, 102 S.Ct. 1584, 1596, 71 L.Ed.2d 816 (1982). The errors alleged by White do not meet this standard.

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