Read the following excerpt from a US court opinion:
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in a limited fashion); Takacs v. Engle, 768 F.2d 122, 124 (6th Cir.1985) (“Coleman’s harmless error analysis remains good law”). Because we cannot conclude that the denial of counsel at the preliminary hearing necessarily undermined the entire criminal proceeding, we will apply a harmless error analysis in this case. 4. We now turn to the salient question of whether the denial of Ditch’s right to counsel at his preliminary hearing was harmless error. To determine whether constitutional error in a habeas case was harmless, we must decide whether the error “had substantial and injurious effect or influence in determining the jury’s verdict.” Brecht v. Abrahamson, 507 U.S. 619, 623, 113 S.Ct. 1710, 123 L.Ed.2d 353 (1993); see also Hassine v. Zimmerman, 160 F.3d 941, 953 (3d Cir.1998) . In making the harmless error determination,
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What is the most suitable continuation to the opinion? Your options are:
A. holding that in order to conclude that federal constitutional error is harmless court must find that error harmless beyond a reasonable doubt
B. holding that a federal habeas court performing a harmless error inquiry on collateral review must employ the standard for harmless error articulated in brecht even if the state courts have never reviewed the error on direct appeal
C. holding that any error was harmless and thus not plain error
D. recognizing that where the error involved defies analysis by harmless error standards or the data is insufficient to conduct a meaningful harmless error analysis then the error will not be proven harmless beyond a reasonable doubt
E. holding exclusion was harmless error
Reply with [A, B, C, D, E] only.