The following excerpt is from Bradford v. Davis, 923 F.3d 599 (9th Cir. 2019):
Cause "must be something external to the petitioner." Id. at 753, 111 S.Ct. 2546. External factors include obstacles such as "a showing that the factual or legal basis for a claim was not reasonably available to counsel," or that "interference by officials ... made compliance impracticable." Murray v. Carrier , 477 U.S. 478, 488, 106 S.Ct. 2639, 91 L.Ed.2d 397 (1986) (internal citations omitted).
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