The following excerpt is from Victory v. Bombard, 570 F.2d 66 (2nd Cir. 1978):
The burden of demonstrating that an erroneous instruction was so prejudicial that it will support a collateral attack on the constitutional validity of a state court's judgment is even greater than the showing required to establish plain error on direct appeal. The question in such a collateral proceeding is "whether the ailing instruction by itself so infected the entire trial that the resulting conviction violates due process," Cupp v. Naughton, 414 U.S. 141, 147, 94 S.Ct. (396) 397, 400, 38 L.Ed.2d 368, not merely whether " . . . the instruction is undesirable, erroneous, or even 'universally condemned,' " id., at 146, 94 S.Ct., at 400.
and further observed:
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