The following excerpt is from Greenawalt v. Ricketts, 943 F.2d 1020 (9th Cir. 1991):
The second exception clearly does not apply. The rule of Enmund, whatever its significance, is not a "watershed rule of criminal procedure" comparable to Gideon v. Wainwright, 372 U.S. 335, 83 S.Ct. 792, 9 L.Ed.2d 799 (1963), the case most often cited in connection with this second exception. Saffle, 110 S.Ct. at 1264.
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