What is the test for making a showing of cause?
MultiRegion, United States of America
The following excerpt is from Poland v. Stewart, 92 F.3d 881 (9th Cir. 1996):
A showing of cause "must ordinarily turn on whether the prisoner can show that some objective factor external to the defense impeded counsel's efforts to comply with the state's procedural rule." Murray v. Carrier,
Page 893
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