What is the test for procedural failure in a federal habeas petition?

Since Griffin procedurally defaulted the constitutional violation he alleges in his petition, he may not present it in federal habeas proceedings unless he first demonstrates that (1) "cause and prejudice" excuses the default, or (2) the dismissal of his appeal would produce "a miscarriage of justice." Kibler v. Walters, 220 F.3d 1151, 1153 (9th Cir.2000). Griffin does not attribute his default to "cause." We limit our review, therefore, to determining whether the miscarriage of justice exception applies.

To establish a "miscarriage of justice," Griffin must "present evidence of

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