Lindsay v. North Central Correctional Complex  ·  2025-03-04  ·  N.D. Ohio  ·  pin 712 F.3d at 283

“a procedural default does not bar consideration of a federal claim on either direct or habeas review unless the last state court rendering a judgment in the case ‘clearly and expressly’ states that its judgment rests on the procedural bar.”

Darryl Gumm v. Betty Mitchell  ·  2014-12-22  ·  Sixth Circuit  ·  pin 712 F.3d at 283

“[A] claim is procedurally defaulted where the petitioner failed to exhaust state court remedies, and the remedies are no longer available at the time the federal petition is filed because of a state procedural rule.”