Whether Rehaif error is structural and requires automatic reversal, or is subject to harmless error review

QUESTION PRESENTED The Fourth Circuit has held that error under Rehaif v. United States, 139 S.Ct. 2191 (2019), is structural; the Ninth Circuit and other courts routinely deem Rehaif error nonprejudicial and decline to cure it. Because jurists of reason can differ on whether Rehaif error is structural, did the Ninth Circuit err in denying petitioner a certificate of appealability under 28 U.S.C. §2253? -i