The following excerpt is from Martin-Trigona v. Shiff, 702 F.2d 380 (2nd Cir. 1983):
12 Our ruling is not as strict as that requiring state prisoners to exhaust all available state remedies before habeas corpus relief can be had from the federal courts, although our holding is born of similar concerns. See Sunal v. Large, 332 U.S. 174, 178, 67 S.Ct. 1588, 1590, 91 L.Ed. 1982 (1947); Riggins v. United States, 199 U.S. 547, 549-50, 26 S.Ct. 147, 148-149, 50 L.Ed. 303 (1905). The orderly administration of justice requires regularity of procedure. See In re Chapman, 156 U.S. 211, 218, 15 S.Ct. 331, 333, 39 L.Ed. 401 (1895). And it is the court's function to enforce the rules designed to ensure regularity and reliability.
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