What is the current state of the law in relation to procedural issues?

MultiRegion, United States of America

The following excerpt is from Cogswell v. Beard, Civil No. 11cv1559-MMA (WVG) (S.D. Cal. 2014):

(9th Cir. 2002), citing Lambrix v. Singletary, 520 U.S. 518, 525 (1997) ("We do not mean to suggest that the procedural-bar issue must invariably be resolved first; only that it ordinarily should be.")

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