dissenting.
Well-settled principles govern this court’s review of a petition for federal habeas corpus filed by a state prisoner after the effective date of the Antiterrorism and Effective Death Penalty Act (AEDPA). Specifically, a federal court may not grant a writ of habeas corpus to a state prisoner on any claim fully adjudicated in state court unless the decision “was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States.” 28 U.S.C. § 2254(d). If a state court applies a rule that contradicts Supreme Court case law, the determination is contrary to clearly established federal law and a writ of habe-as corpus may issue from the federal court. See Williams v. Taylor, 529 U.S. 362, 405, 120 S.Ct. 1495, 146 L.Ed.2d 389 (2000). If a state-court determination correctly identifies governing Supreme Court precedent but misapplies the rule to the facts of the case before it, the state court engages in an unreasonable application of federal law. See Williams, 529 U.S. at 407, 120 S.Ct. 1495. After reviewing the petition and studying the record of the state court proceedings, I must conclude that, in rejecting Mr. Davis’ request to conduct an in camera inspection of Melo-dee Vance’s medical files, the Wisconsin Court of Appeals not only articulated, but also applied, a standard contrary to clearly established Supreme Court precedent. Accordingly, the district court should have *949granted Mr. Davis’ petition for the writ of habeas corpus.
A.
It is well-established that “the government has an obligation to turn over evidence in its possession that is both favorable to the accused and material to guilt or punishment.” Pennsylvania v. Ritchie, 480 U.S. 39, 57, 107 S.Ct. 989, 94 L.Ed.2d 40 (1987) (citing United States v. Agurs, 427 U.S. 97, 96 S.Ct. 2392, 49 L.Ed.2d 342 (1976)). A difficult issue arises, however, when the defendant submits that medical and psychiatric records of the alleged victim that are within the Government’s control contain information both favorable and material to his defense. In such situations, the accused has an important interest in obtaining information from the state that is relevant to his case and, indeed, probative of his guilt or innocence. At the same time, however, the Government and the alleged victim have an equally important interest in shielding from unnecessary disclosure the intensely private contents of medical or psychiatric records.
In an effort to strike a balance between these competing interests, the Supreme Court of the United States, in Pennsylvania v. Ritchie, 480 U.S. 39, 57, 107 S.Ct. 989, 94 L.Ed.2d 40 (1987), articulated general guidelines for when a trial court, at the request of a defendant, must conduct an in camera review of an alleged victim’s confidential or privileged medical records. To obtain such an in camera inspection from the court, the defendant must “at least make some plausible showing” that these documents contain information “both material and favorable to his defense.” Ritchie, 480 U.S. at 58 n. 15, 107 S.Ct. 989. In articulating this standard, the Court acknowledged the practical reality that, without access to the records, an accused cannot articulate with precision the information he seeks. Accordingly, a defendant merely must establish some basis for his contention that the files contain information relevant to his case. See id. Rit-chie thus eschews any requirement that, in order to obtain an in camera inspection of privileged medical records, a defendant must articulate specifically the information he seeks and its relevancy to his claim of innocence. Id. at 57 & 58 n. 15, 107 S.Ct. 989.
B.
In this case, prior to trial, Mr. Davis requested that the state court conduct an in camera inspection of medical, psychiatric and mental health records of the alleged victim, Melodee Vance.1
In support of his motion, Mr. Davis, through counsel, stated:
The defendant believes and asserts that the information contained in the records, reports and documents is material and *950central to his defense, insofar as there is new evidence to indicate that Ms. Vance, at the time of the alleged incident, was suffering from a mental condition which may have significantly impaired or altered her ability to perceive, interpret and relate events as they truly happened.
R.3, Ex.H. To support these contentions, Mr. Davis brought the following factual allegations to the attention of the trial court: Vance, in statements to the police, indicated that she had seen people in her apartment that, in fact, were not present;2 near the time of the alleged assault, Vance had consumed cocaine and alcohol, substances that may have interacted with her prescription drugs; and Vance, a known user of cocaine, may have suffered from drug induced psychological disorders, such as cocaine intoxication delirium.
Although Mr. Davis’ counsel reiterated many of these allegations during arguments on the motion, the trial court denied the request for an in camera inspection of Vance’s medical files. The Wisconsin Court of Appeals agreed, noting that Mr. Davis was “entitled to ... in camera inspection of the victim’s privileged health records only upon showing that they are relevant and may be necessary to a fair determination of guilt or innocence.” R.3, Ex.B, at 2. Moreover, in reaching its conclusion, the state court of appeals emphasized that Mr. Davis had “offered nothing to show that [Vance’s] records showed a preexisting problem of that sort unrelated” to her consumption of cocaine on the night of the assault. Id. at 3.
Although, in many instances, the Wisconsin courts have been faithful to Ritchie, see, e.g., State v. Richard A.P., 223 Wis.2d 777, 589 N.W.2d 674, 677 (1998), it is evident that, in this case, the Wisconsin Court of Appeals departed significantly from the mandates of that decision. Under Ritchie, a trial court must conduct an in camera inspection of the alleged victim’s medical records provided that the defendant makes a “plausible showing” that the documents contain information “both material and favorable to his defense.” Ritchie, 480 U.S. at 58 n. 15, 107 S.Ct. 989. Contrary to this holding, the Wisconsin Court of Appeals required Mr. Davis to proffer specific evidence indicating both the relevance and materiality of these documents to his defense. The state appellate court simply misstated the standard applicable to Mr. Davis’ claims. Moreover, Mr. Davis tendered to the court more than vague allegations that Vance may have suffered from a cocaine induced delirium. These submissions provided a plausible showing that Vance’s medical records may provide further evidence that she suffered from a medical or psychological condition that impaired her ability to perceive on the night of the alleged assault. The Wisconsin Court of Appeals dismissed this showing and concluded that Mr. Davis failed to establish adequately that Vance suffered from a delusional illness that would warrant an in camera review of her files. By requiring the defendant to proffer further evidence in this case, the Wisconsin Court of Appeals adopted the very specificity standard that the Supreme Court had rejected in Ritchie. Therefore, the state-court determination at issue in this case is contrary to the clearly established deci-sional law of the Supreme Court of the United States and, also, is a misapplication of the principles of Ritchie.
*951c.
The majority posits that, even if the trial court should have conducted an in camera review of Vance’s medical files, any resulting error was harmless. In particular, at trial, the prosecution tendered numerous photographs that depicted the injuries that Vance suffered on the night of the incident. According to the majority, the nature of this evidence renders preposterous the defense’s theory that Vance misper-ceived events.
Because the state courts did not address whether the failure to conduct an in camera review constituted harmless error, we must consider the issue without reference to AEDPA’s standards. See Ouska v. Cahill-Masching, 246 F.3d 1036, 1046 (7th Cir.2001); Braun v. Powell, 227 F.3d 908, 916-17 (7th Cir.2000). Under pre-AEDPA standards, in determining whether a constitutional error was harmless, the court determines whether the error “had substantial and injurious effect or influence in determining the jury’s verdict” resulting in “actual prejudice” to the defendant. Brecht v. Abrahamson, 607 U.S. 619, 638, 113 S.Ct. 1710, 123 L.Ed.2d 353 (1993)(citing Kotteakos v. United States, 328 U.S. 750, 776, 66 S.Ct. 1239, 90 L.Ed. 1557 (1946)). Because the federal court is engaging in only a collateral review, “the error in question need not be harmless beyond a reasonable doubt.” Jenkins v. Nelson, 157 F.3d 485, 494 (7th Cir.1998). However, if the court faces “grave doubt as to the harmlessness of the error,” the conviction must be reversed and a writ of habeas corpus issued to the petitioner. O’Neal v. McAninch, 513 U.S. 432, 436, 115 S.Ct. 992, 130 L.Ed.2d 947 (1995).
During Mr. Davis’ trial, the strength of the prosecution’s case rested heavily on Vance’s testimony and the photographs of her injuries.3 Mr. Davis’ defense rested primarily on his view that Vance was not a witness whose testimony can be trusted, given her medical history and drug abuse. In essence, then, Vance’s credibility and her perceptions of the events that transpired on the night of the purported incident proved critical to the conviction of Mr. Davis. Because the trial court declined to conduct an in camera inspection of Vance’s records, no one is able to say definitively whether the documents contained information relevant to Vance’s ability to perceive events. Based on Mr. Davis’ significant showing of Vance’s possible medical and psychological problems, it seems probable that the medical documents may have contained information that would have made a significant difference in the quality of the defense available to Mr. Davis. Under these circumstances, I have grave doubts as to the harmlessness of the error. See O’Neal v. McAninch, 513 U.S. 432, 436, 115 S.Ct. 992, 130 L.Ed.2d 947 (1995). Because of this concern, I must respectfully dissent from the judgment of the court.
. A review of the record makes it evident that the files Mr. Davis sought were not under the direct control of the prosecutor. To the contrary, many of the requested documents resided with the Wisconsin Department of Corrections ("WDOC”). This court's opinion in United States v. Hack, 162 F.3d 937 (7th Cir.1998), may have left the impression that Ritchie only applies to documents within the hands of the prosecutorial authorities. See Hack, 162 F.3d at 947. Such an interpretation of Hack would be erroneous, however. It would be directly at odds with Ritchie. Specifically, in Ritchie, the prosecutor did not possess the documents potentially subject to an in camera review, see Ritchie, 480 U.S. at 44 n. 4, 107 S.Ct. 989; rather, another arm of the state government controlled the files in question. Yet, the Supreme Court indicated that, upon the proper showing, the defendant in Ritchie was entitled to an in camera inspection of these documents.
Notably, at oral argument, the State of Wisconsin disavowed any reliance on a restrictive reading of Hack that would cause it to be in conflict with Ritchie and seemingly conceded that the documents controlled by WDOC fell within Ritchie’s ambit.
. In her motion to the trial court, Mr. Davis’ counsel indicated that Exhibit #1, attached to the motion, corroborated this contention. However, Exhibit # 1, selected pages from the testimony of Vance at the preliminary hearing, contains no reference to Vance having seen people who were not there. Moreover, a review of the remainder of the appellate record does not reveal any other corroboration for this statement.
. The State also produced a witness who testified he heard Vance crying in Mr. Davis' room on the night of the alleged assault. That testimony was partially corroborated by the testimony of a neighbor. There was also medical testimony, testimony which, when evaluated in its totality as it is presented in the appellate record, leaves me with some doubt as to the nature and extent of Vance's injuries.