What is the test for habeas relief in a sexual assault case?

I concur in the judgment and with all of the majority's opinion except the interpretation of footnote nine of Brecht v. Abrahamson, --- U.S. ----, 113 S.Ct. 1710, 123 L.Ed.2d 353 (1993). That troublesome footnote creates a special category of "deliberate and especially egregious error[s] of the trial type" for which habeas relief is available even if the error "did not substantially influence the jury verdict." In my view, this special category of "trial error" is one for which reversal is required unless the state can show the error to have been harmless beyond a reasonable doubt. Because I conclude that the prosecutorial misconduct in this case, although serious, could not have affected the jury's deliberation in any way, I agree with the majority that habeas relief is not warranted.