The following excerpt is from Hiivala v. Wood, 195 F.3d 1098 (9th Cir. 1999):
To demonstrate cause for a procedural default, Hiivala must establish that some external and objective factor impeded his efforts to comply with the state's procedural rule. See Murray v. Carrier, 477 U.S. 478, 488 (1986). Cause may be established, for example, by demonstrating interference by state officials, unavailability of the factual or legal basis for a claim, or a showing of constitutionally ineffective assistance of counsel. See id.
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