The following excerpt is from Uecker v. Yates, No. 2:10-cv-02291-JKS (E.D. Cal. 2011):
59. See Coleman v. Thompson, 501 U.S. 722, 740 (1991) ("The presumption at present applies only when it fairly appears that a state court judgment rested primarily on federal law or was interwoven with federal law, that is, in those cases where a federal court has good reason to question whether there is an independent and adequate state ground for decision.").
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