The following excerpt is from Taylor v. State of Arizona, 471 F.2d 848 (9th Cir. 1972):
On appeal to this court we reversed. Taylor v. United States (9 Cir. 1970) 424 F.2d 271. In remanding, we directed the trial court to make determinations as to (1) whether the prisoner had exhausted his remedies in the state judicial system; (2) whether there was a deliberate bypass of state remedies; (3) whether the admission of the photograph was a product of an illegal search and seizure, violating the Fourth Amendment; and (4) if there was error of constitutional dimension, was it nevertheless harmless error?
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