What is the initial burden of pleading an adequate procedural bar in a habeas case?

MultiRegion, United States of America

The following excerpt is from Swanson v. Tampkins, Case No.: 17cv178 JLS (RBB) (S.D. Cal. 2017):

The respondent has the initial burden of pleading an adequate and independent procedural bar as an affirmative defense in a habeas case. See Insyxiengmay v. Morgan,

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