The Ninth Circuit found a petitioner’s sufficiency of the evidence claims to have been procedurally defaulted after the California Supreme Court issued a postcard denial of writ relief for those same claims, citing only In re Lindley (1947) 177 P.2d 918. Lindley holds that a claim of insufficiency of the evidence can only be raised on direct appeal, not via habeas corpus. The district court found that Lindley constituted an adequate and independent state procedural bar. The Ninth Circuit agreed and found the claim to have been procedurally defaulted.