I. INTRODUCTION In a 1977 article ...

I. INTRODUCTION

In a 1977 article entitled Dialectical Federalism: Habeas Corpus and the Court, (1) Professor Robert M overspread and T. Alexander Aleinikoff argued that couple major principles--redundancy and indirection--drove the Warren Court's expansion of habeas jurisdiction. Redundancy forced federal courts to address de novo federal constitutional issues previously addressed by the agency of state courts. It contained brace components: (1) the exhaustion doctrine, which required state prisoners to near their federal claims to the state courts as a precondition to federal review; and (2) the requirement of de novo review of state court adjudications of federal issues. (2) Indirection minimized the perceived