Pitsch v. Michigan Attorney Grievance Commission

How later courts describe this case

• “[a]t a minimum, ... the petitioner during direct appeal must have explicitly referred the state courts to the United States Constitution or federal case law”
• “At minimum, though, the petitioner during direct appeal must have explicitly referred the state courts to the United States Constitution or federal case law.”
• ‘Were protestation of innocence the only prerequisite to application of this exception, we fear that actual innocence would become a gateway forever open to habeas petitioners’ defaulted claims.”