What is the test for federal habeas corpus relief for a state court's misapplication of its own sentencing laws?

MultiRegion, United States of America

The following excerpt is from Sappenfield v. State of Washington, 120 F.3d 269 (9th Cir. 1997):

" '[F]ederal habeas corpus relief does not lie for errors of state law.' " Estelle v. McGuire, 502 U.S. 62, 67 (1991) (citation omitted). Absent fundamental unfairness, federal habeas relief is not available for a state court's misapplication of its own sentencing laws. See Christian v. Rhode, 41 F.3d 461, 469 (9th Cir.1994). Thus, the petitioner must establish that an error of constitutional significance occurred in order to state a cognizable federal habeas claim. See McGuire, 502 U.S. at 68.

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