The following excerpt is from Heller v. Powers-Mendoza, No. 2:05-cv-02518-JKS (E.D. Cal. 2011):
16. Robinson v. Ignacio, 360 F.3d 1044, 1055 (9th Cir. 2004); cf. Ylst v. Nunnemaker, 501 U.S. 797, 804 (1991) (explaining "how federal courts in habeas proceedings are to determine whether an unexplained order . . . rests primarily on federal law," and noting that federal courts must start by examining "the last reasoned opinion on the claim . . . ").
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