The following excerpt is from Smith v. Mahoney, D.C. No. CV-86-198-M-CCL, No. 94-99003 (9th Cir. 2010):
7.Before the passage of the AEDPA, 28 U.S.C. 2253 required state prisoners seeking to appeal denials of habeas relief to obtain a Certificate of Probable Cause, which could be issued if the prisoner made a substantial showing of the denial of a federal right. Fuller v. Roe, 182 F.3d 699, 702 (9th Cir. 1999).
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