After Reese appealed his state convictions and was denied collateral relief, the Oregon Supreme Court denied him discretionary review. His subsequent federal habeas petition raised a federal constitutional IAC claim. The federal district court held that Reese had not “fairly presented” this claim to the state courts because his brief had not indicated that he was complaining about a federal law violation. The Ninth Circuit reversed, finding that the requirement was satisfied becasue the Supreme Court justices had the opportunity to read the lower court decision before deciding whether to grant discretionary review, and if they had read it, they would have or should have realized that his claim rested on federal law. The U.S. Supreme Court here reversed the Ninth Circuit judgment, holding that a state prisoner does not “fairly present” a federal claim to a state court if that court must read beyond a petition or brief to find material to alert it to the presence of such a claim. To require the appellate courts to read lower court opinions in every case would impose a serious burden on those judges.