When two state procedural bars are invoked in a single order disposing of multiple claims in a personal injury case, can the state be deemed to be inconsistent with the other state?
MultiRegion, United States of America
The following excerpt is from Taylor v. Beard, Civil No. 11cv1165-BTM (BLM) (S.D. Cal. 2014):
Washington v. Cambra, 208 F.3d 832, 834 (9th Cir. 2000) (holding that when two state procedural bars are invoked in a single order disposing of multiple claims, the ambiguity precludes procedural default unless both bars are adequate and independent.)
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