Can a lower court avoid a decision on the merits of a habeas petition because of technicality?

Nigro argues that the lower court avoided the merits of his habeas petition because of mere technicality. Citing Schiavone v. Fortune, 477 U.S. 21, 106 S.Ct. 2379, 91 L.Ed.2d 18 (1986), he notes that "decisions on the merits are not to be avoided on the basis of mere technicalities." Id. at 27, 106 S.Ct. at 2383 (internal quotations omitted). We are not persuaded. Schiavone and the cases it cites address whether civil pleadings sufficiently alleged information necessary to set out a claim against another party. Schiavone does not address whether a procedural default in seeking administrative remedies warrants dismissal of a habeas petition, however. Procedural default will support a dismissal, even if technically inadequate pleadings will not. Procedural default is therefore not a mere technicality.