What is the test for whether a federal Habeas Petitioner has exhausted all of his state remedies before filing a federal petition?

equitably tolled if a petitioner establishes "'(1) that he has been pursuing his rights diligently, and (2) that some extraordinary circumstance stood in his way' and prevented timely filing." Holland v. Florida, 560 U.S. 631, 649 (2010) (quoting Pace v. DiGuglielmo, 544 U.S. 408, 418 (2005)).

Habeas petitioners are required to exhaust state remedies before seeking relief in federal court. 28 U.S.C. 2254(b). When a petitioner seeks to add newly-exhausted claims to a timely-filed federal petition after the limitations period has expired, the amendments will be considered timely if they relate back to the original petition within the meaning of Rule 15 of the Federal Rules of Civil Procedure. Mayle v. Felix, 545 U.S. 644 (2005).

IV. Analysis

A. The 2012 Federal Petition Was Timely