In Brecht v. Abrahamson, 507 U.S. 619 (1993), the Court addressed the issue of harmless error in the context of collateral review. The Court explained that "the writ of habeas corpus has historically been regarded as an extraordinary remedy, a bulwark against convictions that violate fundamental fairness. Those few who are ultimately successful in obtaining habeas relief are persons whom society has grievously wronged and for whom belated liberationis little enough compensation." Id. at 633-34. Accordingly, the Court determined that "habeas petitioners may obtain plenary review of their constitutional claims, but they are not entitled to habeas relief based on trial error unless they can establish that it resulted in 'actual prejudice.'" Id. at 637. This standard requires a court to determine "whether the error had substantial and injurious effect or influence in determining the jury's verdict." Id. Of course, harmless error analysis applies to errors commonly referred to as "trial errors." In Brecht, the Supreme Court distinguished between errors of this type and "structural defects." Trial error occurs during the presentation of the case to the jury, and is amenable to harmless-error analysis because it may . . . be quantitatively assessed in the context of other evidence presented in order to determine the effect it had on the trial. At the other end of the spectrum of constitutional errors lie structural defects in the constitution of the trial mechanism, which defy analysis by harmless-error standards. The existence of such defects--deprivation of the right to counsel, for example--requires automatic reversal of the conviction because they infect the entire trial process. Id. at 629-30. The Supreme Court explained that a federal court in habeas must generally review a state court's decision using a strict "harmless error" standard, but that cases involving "structural" or "hybrid" error require reversal regardless of harm. In making these observations, however, the Court did not purport to enlarge the power of federal courts to grant relief under 28 U.S.C. 2254(d)(1). Brecht does not hold that structural or hybrid error requires reversal even when the trial court has not committed a violation of clearly established federal law. It held only that, if "structural" or "hybrid" error occurs, harmless error review is inappropriate. Under the AEDPA, we simply cannot grant relief unless we find a violation of "clearly established" federal law, even if the error complained of is "structural."