The following excerpt is from King v. Davey, No. 2:16-cv-1464-WBS-EFB P (E.D. Cal. 2019):
To prevail in federal habeas proceedings, a petitioner must establish the applicability of one of the 2254(d) exceptions and also must affirmatively establish the constitutional invalidity of his custody under pre AEDPA standards. Frantz v. Hazey, 533 F.3d 724 (9th Cir. 2008) (en banc). There is no single prescribed order in which these two inquiries must be conducted. Id. at
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