The following excerpt is from Rodriguez v. Hatton, No. 1:16-cv-00180-JLT (HC) (E.D. Cal. 2017):
To be deemed adequate, the state law ground for decision must be well-established and consistently applied. Poland v. Stewart, 169 F.3d 573, 577 (9th Cir. 1999) ("A state procedural rule constitutes an adequate bar to federal court review if it was 'firmly established and regularly
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