The following excerpt is from Otto v. Tampkins, No. 2:19-cv-00425 MCE GGH P (E.D. Cal. 2019):
A state court has had an opportunity to rule on the merits of a claim when the petitioner has fairly presented that claim to that court. The fair presentation requirement is met where the petitioner has described the operative facts and legal theory on which his claim is based. Picard, 404 U.S. at 277-78. Generally, it is "not enough that all the facts necessary to support the federal claim were before the state courts ... or that a somewhat similar state-law claim was made." Anderson v. Harless, 459 U.S. 4, 6 (1982). Mere "general appeals to broad constitutional principles, such as due process, equal protection, and the right to a fair trial," do not establish
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