The following excerpt is from Alcantar v. Foulk, Case No. 1:14-cv-00747 LJO MJS (HC) (E.D. Cal. 2016):
are the principal forum for asserting constitutional challenges to state convictions." Id. at 787. It follows from this consideration that 2254(d) "complements the exhaustion requirement and the doctrine of procedural bar to ensure that state proceedings are the central process, not just a preliminary step for later federal habeas proceedings." Id. (citing Wainwright v. Sykes, 433 U.S. 72, 90 (1977)).
3. Prejudicial Impact of Constitutional Error
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