The following excerpt is from Aguilar v. Cate, Case No.: 1:12-cv-01547-LJO-JLT (E.D. Cal. 2015):
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
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