When the California Supreme Court denied Hill’s habeas petition, it issued a letter stating in full: “Petition for writ of habeas corpus is DENIED. (In re Waltreus (1965) 62 Cal.2d 218, 225; People v. Hill (1973) 9 Cal.3d 784, 786, 787.)” The federal district court held that the Supreme Court’s citation to Waltreus did not bar federal court review, but that its citation to Hill did because it’s reference to Hill implies a denial of the state habeas on an independent and adequate state procedural bar. Under the independent and adequate state grounds doctrine, federal courts are barred from reconsideration of the issue as long as the state court explicitly invokes a state procedural bar rule as a basis for its decision. The question here is whether the state court’s reference to these two cases invoked the doctrine. In re Waltreus provides that habeas corpus ordinarily cannot serve as a second appeal. This does not bar federal court review. The Hill case says that a petitioner may not raise an issue in a state habeas petition that has been litigated at trial and considered on direct appeal unless it relates to innocence or guilt. Whether this is an “adequate state procedural rule” depends on whether it is strictly or regularly followed and consistently applied. The burden of proving “adequacy” is on the People, then the burden shifts to the petitioner to assert specific allegations to demonstrate inadequacy; the ultimate burden then shifts back to the People. Because this is a new standard, the case was remanded for reconsideration of whether the procedural rule stated in Hill is “adequate.”