The following excerpt is from Jackson v. Conway, Docket No. 11-922-pr(L), Docket No. 11-972-pr(XAP) (2nd Cir. 2014):
A state prisoner's procedural default in the state courts will also bar federal review except in narrow circumstances not relevant here. A procedural default occurs in one of two ways. First, if the state prisoner fails to exhaust his state remedies in a manner in which, were he to return to the state courts with his unexhausted claim, those courts would find the claim barred by the application of a state procedural rule, "we 'must deem the claim procedurally defaulted.'" Id. (quoting Aparicio v. Artuz, 269 F.3d 78, 90 (2d Cir. 2001))
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