The following excerpt is from Pao v. Lewis, 2: 10 - cv - 758 - MCE TJB (E.D. Cal. 2011):
(explaining that a district court may address the merits without reaching procedural issues where the interests of judicial economy are best served by doing so); cf. Franklin v. Johnson, 290 F.3d 1223, 1232 (9th Cir. 2002) ("Procedural bar issues are not infrequently more complex than the merits issues presented by the appeal, so it may well make sense in some instances to proceed to the merits if the result will be the same.").
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