The following excerpt is from Blank v. Brown, No. 2:13-cv-0217 TLN CKD (E.D. Cal. 2014):
It is the habeas petitioner's burden to show he is not precluded from obtaining relief by 2254(d). See Woodford v. Visciotti, 537 U.S. 19, 25, 123 S. Ct. 357, 154 L.Ed.2d 279 (2002).
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