Can a state prisoner obtain independent federal review of admission of bad act testimony by alleging that the admission violated due process?

A state prisoner can obtain independent federal review of admission of bad act testimony by alleging that the admission violated due process. See Reiger v. Christensen, 789 F.2d 1425, 1431 (9th Cir.1986) (admission of testimony that petitioner

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We find that Terrovona's passing references to the right to a fair trial and the fourteenth amendment are sufficient to allege that the admission violated due process. See Eldridge v. Block, 832 F.2d 1132, 1137 (9th Cir.1987) (courts should construe pro se petitions liberally). Since the district court did not examine the record, we remand to the district court for an independent review of the state's proceedings with respect to the admission of the bad act testimony. Reiger, 789 F.2d at 1431-32 (the district court's failure to conduct an independent review warrants a remand to review the transcript of state proceedings).

6. Exhaustion of Remedies