The following excerpt is from Johns v. McFadden, 24 F.3d 247 (9th Cir. 1994):
At the outset, we reject the government's contention that petitioner has procedurally defaulted on his double jeopardy, ineffective assistance of counsel, and entrapment claims. While petitioner's references to the claims he now raises on federal habeas were undeniably vague, courts are required to liberally construe pro se pleadings, and address any claims that are supported therein. See, e.g., Haines v. Kerner 404 U.S. 519 (1972); Hays v. Arave, 977 F.2d 475, 477 n. 1 (9th Cir.1992). In this case, it appears that petitioner's supplemental brief set forth the essence of his legal claims, thereby giving the Arizona courts adequate opportunity to address them.
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