What is the test for habeas relief in this case?

Washington fares no better on federal habeas review. First, to the extent he contends that the trial court's failure to instruct the jury on second-degree murder or involuntary manslaughter was erroneous under state law, his claim is not cognizable on federal habeas review. See Estelle, 502 U.S. at 71-72 ("[T]he fact that [a jury] instruction was allegedly incorrect under state law is not a basis for habeas relief."); Van Pilon v. Reed, 799 F.2d 1332, 1342 (9th Cir. 1986) (citation omitted).