The following excerpt is from Guerrero v. Muniz, Case No. 1:16-cv-01433-LJO-JDP (HC) (E.D. Cal. 2019):
If a state court denies a petitioner's habeas claim solely on a procedural ground, then Section 2254(d)'s deferential standard does not apply, see Visciotti v. Martel, 862 F.3d 749, 760 (9th Cir. 2016), but the petitioner faces another hurdle: if the state court's decision relies on a state procedural rule that is "firmly established and regularly followed," the petitioner has
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