With no explanation, chose the best option from "A", "B", "C" or "D". clearly established precedent for his position”); Lieberman v. Thomas, 505 F.3d 665, 672 (7th Cir.2007) (“Nowhere in the petition does Lieberman demonstrate how the state appellate court’s opinion conflicts with, or unreasonably applied, relevant Supreme Court precedent....”). Crockett’s factual challenge focuses upon the Illinois Appellate Court’s determination that Crockett failed to show that the trial court unreasonably delayed in informing defense counsel of the note prior to the verdict. Crockett claims that the record shows the trial court did unreasonably delay, and the Illinois Appellate Court’s conclusion to the contrary was unreasonable in light of the evidence. Applying the standard from Brecht v. Abrahamson, 507 U.S. 619, 637, 113 S.Ct. 1710, 123 L.Ed.2d 353 (1993) (<HOLDING>), he claims that the error had a substantial

A: holding that an error must have a substantial and injurious effect on the verdict to entitle a petitioner to habeas relief
B: holding that for habeas relief to be granted based on constitutional error in capital penalty phase error must have had substantial and injurious effect on the jurys verdict in the penalty phase
C: holding that states improper use of defendants postmiranda silence was error but did not warrant habeas relief unless error had a substantial and injurious effect or influence on the jurys verdict
D: holding that a substantial right is affected when the error had a substantial and injurious effect or influence in determining the jurys verdict
A.