dissenting.
This case presents the question whether a federal court may entertain a habeas corpus petition, without a showing of cause and prejudice, if the state court to which the federal *272claim was presented mentions a procedural default, yet considers also the merits of the claim. The majority holds that federal habeas courts must reach the merits of the federal issue absent explicit reliance on the bar, evidenced by a “plain statement” in the state court’s opinion.
Two premises underlie today’s holding. First, although the case before us is a federal habeas corpus proceeding, the majority explores whether an ambiguous reference to a state procedural bar would deprive us of jurisdiction in a matter here on direct review. The majority discovers that the rule of Michigan v. Long, 463 U. S. 1032 (1983), designed for cases where a state court explicitly relies on a state substantive ground that appears to be interwoven with federal law, applies as well in any direct review case where there is ambiguity concerning whether the state court intended to rely on a procedural bar. Thus fortified by its enhanced Long rule, the majority turns to the case before us. It stakes out the second premise, which is that direct review and collateral attack cases should be governed by the same rule. The majority therefore concludes that federal habeas courts must apply Long in determining whether a state court’s reference to a procedural bar triggers the cause-and-prejudice inquiry prescribed by Wainwright v. Sykes, 433 U. S. 72 (1977). Disagreement with each of the majority’s premises elicits my respectful dissent.
I
It is settled law that “where the judgment of a state court rests upon two grounds, one of which is federal and the other non-federal in character, our jurisdiction fails if the non-federal ground is independent of the federal ground and adequate to support the judgment.” Fox Film Corp. v. Muller, 296 U. S. 207, 210 (1935). The rule was first announced to deny our authority to revise state-court judgments resting on an alternative state substantive ground, e. g., Murdock v. Memphis, 20 Wall. 590, 636 (1875), and later was extended to bar our direct review of state judgments that rest on ade*273quate and independent state procedural grounds. See, e. g., Henry v. Mississippi, 379 U. S. 443, 446 (1965); Herndon v. Georgia, 295 U. S. 441 (1935). It follows that where a state court refuses to consider federal claims owing to a criminal defendant’s failure to comply with a state procedural rule that is otherwise adequate and independent, we lack authority to consider the claims on direct review.
Our discussions of this jurisdictional principle have identified circumstances where state procedural grounds are “inadequate” to support the result below, e. g., Johnson v. Mississippi, 486 U. S. 578, 587-589 (1988); James v. Kentucky, 466 U. S. 341, 348-349 (1984), and where state procedural grounds cannot be deemed “independent” of the underlying federal rights, e. g., Ake v. Oklahoma, 470 U. S. 68, 74-75 (1985). An analogous body of doctrine aids us in assessing the independence of state substantive grounds. See, e. g., Enterprise Irrigation Dist. v. Farmers Mutual Canal Co., 243 U. S. 157, 164 (1917). As might be expected in light of the common history and purposes of these doctrines, there is a significant degree of overlap. Our precedents declare, however, that “it is important to distinguish between state substantive grounds and state procedural grounds,” Henry v. Mississippi, 379 U. S., at 446, and caution against the indiscriminate application of principles developed in cases involving state substantive grounds to cases involving procedural defaults. See id., at 447. See also Wainwright v. Sykes, supra, at 81-82. These well-understood principles ensure our respect for the integrity of state-court judgments.
In Michigan v. Long, supra, we considered our jurisdiction to review a judgment of the Supreme Court of Michigan that had ruled a search unlawful. The state court’s opinion had relied almost exclusively on federal decisions construing the Fourth Amendment, though it twice cited an analogous state constitutional provision. 463 U. S., at 1043. After a review of our precedents considering whether various forms of references to state law constitute adequate and independent-state *274grounds, we adopted a presumption in favor of federal review “when ... a state court decision fairly appears to rest primarily on federal law, or to be interwoven with the federal law, and when the adequacy and independence of any possible state law ground is not clear from the face of the opinion . . . .” Id., at 1040-1041.
Our resolution of these ambiguities in favor of federal review rested on this critical assumption: When the state court’s judgment contains no plain statement to the effect that federal cases are being used solely as persuasive authority, and when state law is interwoven with federal law, we can “accept as the most reasonable explanation that the state court decided the case the way it did because it believed that federal law required it to do so.” Id., at 1041 (emphasis added). Our approach, we added, had the further advantage of not requiring us to interpret state laws with which we are generally unfamiliar. Id.., at 1039, 1041.
There may be a persuasive argument for applying Long to cases coming to this Court on direct review where the independence of a state procedural ground is in doubt because the state rule is interwoven with federal law. An example would be if “the State has made application of the procedural bar depend on an antecedent ruling of federal law, that is, on the determination of whether federal constitutional error has been committed.” Ake v. Oklahoma, supra, at 75. See also Longshoremen v. Davis, 476 U. S. 380, 388 (1986). But that situation is not presented in the case before us. In Illinois, “a defendant who neglects to raise a claim of inadequate representation on direct appeal may not later assert that claim in a petition for post-conviction relief,” United States ex rel. Devine v. DeRobertis, 754 F. 2d 764, 766, and n. 1 (CA7 1985) (collecting cases), though “strict application of [this] doctrine . . . may be relaxed . . . ‘where fundamental fairness so requires.’” People v. Gaines, 105 Ill. 2d 79, 91, 473 N. E. 2d 868, 875 (1984), cert. denied, 471 U. S. 1131 (1985), quoting People v. Burns, 75 Ill. 2d 282, 290, 388 N. E. 2d 394, 398 *275(1979). Petitioner does not claim that federal constitutional analysis is somehow determinative of “fundamental fairness” under Illinois law, or even that uncertainty exists on this point. Under the circumstances, “[t]here is no need for a plain statement indicating the independence of the state grounds since there was no federal law interwoven with this determination.” Pennsylvania v. Finley, 481 U. S. 551, 563 (1987) (Brennan, J., dissenting), citing Michigan v. Long, 463 U. S., at 1041.
The purported ambiguity in this case is much dissimilar from the ambiguity we confronted in Long.1 In Long “[t]he references to the State Constitution in no way indicated] that the decision below rested on grounds in any way independent from the state court’s interpretation of federal law,” id., at 1044 (emphasis in original), thus raising the question whether the state court “decided the case the way it did because it believed that federal law required it do so.” Id., at 1041. See also Pennsylvania v. Finley, supra, at 570 (Stevens, J., dissenting). The question in this case does not remotely implicate the independence of the state-law ground from federal law. The alleged ambiguity in the Illinois Appellate Court’s opinion relates instead to whether the state ground was invoked at all. The majority does not explain why adopting the Michigan v. Long presumption in this different context is sensible. It seems to me it is not.
*276Applied to this case, the “most reasonable explanation” test of Michigan v. Long suggests that the Illinois court referred to petitioner’s procedural default to rely on it, not because it was an interesting aside. The State’s rule is that failure to raise a claim on appeal is a waiver. The rule has an exception, presumably intended to apply to a smaller number of cases than the general rule of waiver, that operates to lift the procedural bar when justice so requires. Other States have adopted procedural default rules of like structure, see, e. g., Roman v. Abrams, 822 F. 2d 214, 222 (CA2 1987) (discussing analogous New York rule), cert, pending, No. 87-6154, and it may fairly be assumed that most procedural bars are in fact subject to some exception, even if a quite narrow one. There is no empirical or logical support, however, for the view that the most reasonable explanation for a court’s reference to the general rule is that the court intends to rely on some exception it does not mention. On the contrary, it is most unreasonable to adopt a rule that assumes either that state courts routinely invoke exceptions to their procedural bars without saying so, or that those courts are in the habit of disregarding their own rules.2
Indeed, if the majority’s aim is to devise a bright-line rule that will explain best the greatest number of similarly ambiguous state-court opinions, it should announce the mirror image of the rule adopted today. It should presume that the procedural bar was invoked unless the state court, by a “plain *277statement,” specifically relied on an exception. This alternative rule would serve the majority’s apparent concern for clarity in equal measure, and would be a far more accurate assessment of the intent of the state court in most cases. This rule would have the additional advantage of not presuming that a state court has disregarded its own laws in those instances where there is either no exception to the bar or an exception that manifestly is inapplicable to the defendant. Cf. Black v. Romano, 471 U. S. 606, 615 (1985) (“We must presume that the state judge followed [state] law”).
It is makeweight and unconvincing, moreover, to justify the majority’s extension of Michigan v. Long on the basis of our interest in avoiding unnecessary inquiries into “state laws with which we are generally unfamiliar.” Michigan v. Long, supra, at 1039.3 This concern is slight when the state-law ground is procedural rather than substantive. The doctrine of adequacy developed in the context of procedural bars already requires us to conduct extensive reviews of questions of state procedural law in order to determine whether the State’s “procedural rule is ‘strictly or regularly followed,’” Johnson v. Mississippi, 486 U. S., at 587, quoting Barr v. Columbia, 378 U. S. 146, 149 (1964), for state courts “may not avoid deciding federal issues by invoking procedural rules that they do not apply evenhandedly to all similar claims.” Hathorn v. Lovorn, 457 U. S. 255, 263 (1982). If this Court is institutionally capable of assessing whether a state procedural rule has been applied “evenhandedly to all similar claims,” it is certainly capable of assessing *278whether, in any given case, an exception to a procedural bar is applicable and has been invoked.4
The Court sidesteps the obvious difficulties of its new rule by stating that our decision in Caldwell v. Mississippi, 472 U. S. 320 (1985), already held that any ambiguity concerning whether a state court actually relied on a procedural bar “must be resolved by application of the Long standard.” Ante, at 262. It is true that Caldwell addressed the question whether the state court had relied on a procedural bar, and that it referred to Michigan v. Long in indicating, somewhat obliquely, that the lower court opinion did not contain an explicit statement that the decision was based on state law. 472 U. S., at 327. While Caldwell perhaps is not entirely clear on the point, it is difficult to view these statements as announcing conclusively that the Long presumption applies in all cases where there is doubt concerning whether a state court intended to rely on a procedural bar.
In any event, our references to the Long rule in Caldwell were entirely unnecessary to the decision, and the majority’s uncritical interpretation of Caldwell as controlling authority here is misplaced. In Caldivell two reasons persuaded us to reject the State’s argument that a procedural bar deprived us of jurisdiction. First, our own review of the state court’s opinion persuaded us that it could be “read . . . only as meaning that procedural waiver was not the basis of the decision.” Caldwell, supra, at 328 (emphasis added). Because we explicitly found that there was no ambiguity concerning whether the state court intended to rely on the procedural default, our references to Long ought not to be interpreted as requiring that Long be applied in cases where we are faced with such an ambiguity. Second, our opinion in Caldwell noted that Mississippi had not consistently applied *279its procedural bar to capital cases. 472 U. S., at 328. Caldwell’s citation of Michigan v. Long therefore cannot be characterized as holding that a procedural bar will oust this Court of jurisdiction only if the opinion below included the “plain statement” so eagerly sought by today’s majority. The State’s inconsistent application of its procedural bar would have rendered its bar inadequate in Caldwell, even if the state court had explicitly relied on it. See, e. g., Johnson v. Mississippi, supra, at 587-589. Caldwell ought not to be interpreted to require application of Long’s plain statement rule to the situation before us when the plainest possible statement could not have deprived us of jurisdiction in Caldwell itself.
I remain convinced that our reasoning in Michigan v. Long does not extend to a situation where, as here, there is doubt about whether a state court intended to rely on a procedural bar, but where there is no ambiguity, as there was in Long, concerning whether the bar is independent from federal law. Facial ambiguities that relate solely to whether a state court did invoke a procedural bar should not be resolved uncritically in favor of federal review.
II
Even if the majority were correct in concluding that the judgment of the Illinois Appellate Court would have been reviewable in this Court under Michigan v. Long, it errs in concluding that federal habeas review must also be available. The equivalence the majority finds between direct and collateral review appears to be based on two arguments. First, the majority asserts that Wainwright v. Sykes, 433 U. S. 72 (1977), “made clear that the adequate and independent state ground doctrine applies on federal habeas.” Ante, at 262. Second, the Court argues that the “substantial” benefits of extending Michigan v. Long to the habeas context outweigh any state interests that may be burdened by applying Long in this context. Neither argument is persuasive.
*280Far from supporting the majority’s reflexive extension of Long to habeas cases, Wainwright v. Sykes made clear, after an exhaustive review of our precedents, that the adequate and independent state ground doctrine does not “apply” in the habeas context in the manner suggested by the Court today. As Sykes noted, our decision in Fay v. Noia, 372 U. S. 391 (1963), explicitly divorced the doctrines governing our appellate jurisdiction from those governing the power of the federal courts to entertain habeas corpus applications. Wainwright v. Sykes, supra, at 82-83; Fay v. Noia, 372 U. S., at 425-426, 433-434. Under the view we took of the habeas corpus statute in Fay, the state court’s reliance on its procedural rule, even if sufficient to preclude direct review of the state-court judgment, could not prevent a federal habeas court from considering the underlying constitutional claim. It was only as a matter of comity that we recognized the principle that habeas review could be denied to an “applicant who ha[d] deliberately by-passed the orderly procedure of the state courts and in so doing ha[d] forfeited his state court remedies.” Id., at 438.
Our decision in Sykes placed some limits on the expansive regime of Fay v. Noia, but reaffirmed that comity and federalism are the principles that control the weight that a federal habeas court should accord to a state procedural default. These constitutional concerns, not some mechanical application of the doctrines governing our appellate jurisdiction, formed the basis for our holding that a state procedural default will preclude federal habeas review unless the applicant shows both cause for failing to comply with the State’s rule and actual prejudice resulting from the alleged constitutional violation.5 433 U. S., at 84-91. Indeed, the majority’s re*281affirmation of the authority of federal courts to grant habeas relief, notwithstanding a procedural default, on a showing of “cause and prejudice” belies any facile equivalence between direct and collateral review. The significance of Sykes for this case has nothing to do with “adequate and independent state grounds,” but with principles governing the relationship between federal and state courts that have become an essential part of our judicial federalism.
Because our decision to honor state procedural defaults in habeas cases is intended “to accord appropriate respect to the sovereignty of the States in our federal system,” Ulster County Court v. Allen, 442 U. S. 140, 154 (1979), any determination that a state court did not intend to rely on a procedural default must be made with the same deference to the State’s sovereignty that motivates our willingness to honor its procedural rules in the first place. The majority’s second argument for extending Michigan v. Long to the habeas context seems to acknowledge as much, for at least it purports to be guided by those principles of federalism and comity that until now have informed our analysis. Ante, at 263-265. The majority’s perfunctory discussion of these principles, however, is inadequate to justify its view that extending Long will burden state interests “minimally, if at all,” ante, at 264, while producing “substantial” benefits. Ibid. These conclusions, in my view, reflect a miserly assessment of the State’s interest and an extravagant notion of the benefits to be derived from extending Long to habeas cases.
The majority dismisses the State’s interests by positing that state courts have become familiar with the “plain statement” rule under Long. One may question whether it is not *282“unrealistic — and quite unfair — to expect the judges [who must deal with postconviction proceedings in the lower state courts] to acquire and retain familiarity with this Court’s jurisprudence concerning the intricacies of our own jurisdiction.” Pennsylvania v. Finley, 481 U. S., at 570 (Stevens, J., dissenting). In any event, the majority’s improvident extension of Michigan v. Long burdens significant state interests that today’s opinion does not even acknowledge. As we emphasized at great length in Engle v. Isaac, 456 U. S. 107, 126-128 (1982), federal habeas review itself entails significant costs. It disturbs the State’s significant interest in repose for concluded litigation, denies society the right to punish some admitted offenders, and intrudes on state sovereignty to a degree matched by few exercises of federal judicial authority. The majority’s new rule can only increase the likelihood that these costs will be incurred more often.
The majority’s opinion also reflects little consideration of the perverse incentives created by its holding. Because an ambiguous state-court order will ensure access to a federal habeas forum, prisoners whose claims otherwise would be procedurally barred now have every incentive to burden state courts with a never-ending stream of petitions for post-conviction relief. Such perseverance may, in due course, be rewarded with a suitably ambiguous rebuff, perhaps a one-line order finding that a prisoner’s claim “lacks merit” or stating that relief is “denied.” Instead of requiring prisoners to justify their noncompliance with state procedural rules, as contemplated by the cause-and-prejudice standard, the majority’s decision openly encourages blatant abuse of state-court processes and circumvention of the standard established in Sykes.6
*283The majority’s explanation of the questionable advantages of its new rule does not allay these concerns. The majority appears to think that state procedural rules are so arcane that the federal district courts and courts of appeals should not be burdened with the task of determining their controlling effect. We have recognized, however, that those courts are experts in matters of local law and procedure. See, e. g., Rummel v. Estelle, 445 U. S. 263, 267, n. 7 (1980) (deferring to the Fifth Circuit’s conclusion that petitioner was not procedurally barred under Texas law); Ulster County Court v. Allen, supra, at 153-154 (noting deference owed to the Second Circuit’s conclusion that New York court decided constitutional issue on the merits); Brown v. Allen, 344 U. S. 443, 458 (1953) (“So far as weight to be given the proceedings in the courts of the state is concerned, a United States district court, with its familiarity with state practice is in a favorable position to recognize adequate state grounds in denials of relief by state courts without opinion”). Indeed, far from regarding decisions of state-law questions as “substantial burdens on the federal courts,” ante, at 264, our precedents reveal that a federal court’s ability to dispose of cases on state-law grounds is an affirmatively desirable means of avoiding, if possible, federal constitutional questions. See, e. g., Pennhurst State School and Hospital v. Halderman, 465 U. S. 89, 117, 119, n. 28 (1984); Ashwander v. TVA, 297 U. S. 288, 347 (1936) (Brandeis, J., concurring); Delaware v. Van Arsdall, 475 U. S. 673, 693, n. 5 (1986) (Stevens, J., dissenting). Our limited familiarity with local law may require some relaxation of this salutary principle in this Court, *284but the majority offers no sound reason for thinking that the other federal courts are in dire need of such a dispensation, especially when it is conferred at the cost of an undetermined increase in the number of cases to be resolved on the merits.
Even assuming that avoidance of state-law questions is now considered an unalloyed blessing as a general matter, those questions cannot be avoided in federal habeas cases. To cite only the most obvious reason, the habeas statute and our decisions preclude habeas relief “unless it appears that the applicant has exhausted the remedies available in the courts of the State, or that there is either an absence of State corrective process or the existence of circumstances rendering such process ineffective to protect the rights of the prisoner.” 28 U. S. C. § 2254(b). See Granberry v. Greer, 481 U. S. 129, 133-134 (1987); Picard v. Connor, 404 U. S. 270, 275 (1971); Ex parte Hawk, 321 U. S. 114, 116-118 (1944). Our cases recognize that this requirement refers only to remedies still available at the time of the federal habeas petition, and that no such remedies are in fact available if the state courts would refuse to entertain the claim because of a procedural default. Engle v. Isaac, supra, at 125-126, n. 28. Thus, federal habeas courts must become familiar with state rules governing procedural defaults and with the. circumstances when exceptions to these rules will be invoked. Because the unequivocal command of § 2254(b) already requires that federal courts become experts on the procedural rules that govern the availability of postconviction relief in the state courts, the majority’s assessment of the marginal burdens imposed on federal courts by the need to construe those rules in cases like the one before us can only be described as extravagant.
Our decision in Engle v. Isaac, supra, which the Court strongly reaffirms in this case and in two other cases decided today, ante, at 263, n. 9; Castille v. Peoples, post, p. 346; Teague v. Lane, post, p. 288, thus belies the majority’s assessment of the benefits of its new rule. Engle also *285indicates that there is a difficulty even more fundamental with the majority’s reasoning. The majority’s premise, indeed the driving force of its holding, appears to be that there is always a possibility that the state courts will forgive a procedural default irrespective of how clear state law may be to the contrary. But this premise is not credited even by the majority. If this premise were true, Engle would be overruled, not reaffirmed. If forgiveness were always a realistic possibility, no federal habeas court could ever invoke Engle, for no federal court could be sure, in any given case, that the state courts would refuse to consider a federal claim on the basis of the state’s procedural default rules.
According to the majority, two different rules will guide the lower courts’ consideration of procedural default issues after today. On the one hand, if a defendant presents his claims to the courts of the State, the majority’s new rule applies. A federal habeas court faced with an ambiguous state-court opinion may not consult state-law sources to determine whether the state court is authorized to forgive the procedural default, or to decide whether the circumstances in which a default may be overlooked consistent with state law are present in the particular case. On the other hand, if a defendant has never attempted to raise his claim in the courts of the State, Engle applies. A federal habeas court faced with such a case must look to state law to decide whether the petitioner is procedurally barred and whether the state courts are likely to waive his procedural default. The federal court must apply our holding in Wainwright v. Sykes, 433 U. S. 72 (1977), if the court concludes, on the basis of such review, that the state courts would likely refuse to entertain the petitioner’s claim. Yet it is obvious that Engle and the rule adopted by the majority in this case are based on irreconcilable assumptions about the regularity and predictability of state procedural rules. And it is not difficult to predict that the lower courts, faced with inconsistent pro*286nouncements from this Court, soon will require us to choose one principle or the other.
Nothing could illustrate this point better than the Court’s decision in Teague v. Lane, post, p. 288. The petitioner in Teague, like Harris, failed to raise one of his federal constitutional claims on direct appeal in the Illinois courts. Under the same Illinois procedural rule at issue in the present case, the petitioner in Teague is barred from raising his claim in collateral proceedings unless fundamental fairness requires that his default be overlooked. Speaking for four Members of the Court, Justice O’Connor concludes that the petitioner in Teague has exhausted his state remedies because, in view of the limited scope of the fundamental fairness exception, the Illinois courts clearly would refuse to entertain the merits of his claim in collateral proceedings. For the same reason, the Teague plurality concludes that the petitioner in that case is procedurally barred. Teague v. Lane, post, at 297-299. Without disagreeing with the plurality’s conclusion on these logically antecedent issues, Justice White concurs in the judgment disposing of the case on retroactivity grounds. Post, at 317. It appears therefore that five Members of the Court are of the view that it would be entirely futile to remand the case to the Illinois courts because those courts enforce their procedural default rules strictly. The majority does not explain, and I fail to see, how this conclusion can possibly be squared with the majority’s adoption of a conclusive presumption to the contrary in the present case.
In sum, the Court’s decision to extend Michigan v. Long to the habeas context ignores important state interests that it is our tradition to honor, and advances no significant federal interest. Indeed, the Court’s new rule works against the important federal interests of avoiding, if possible, decisions on federal constitutional claims, and stemming the overwhelming tide of prisoner petitions. Neither logic nor precedent requires this perverse result.
*287h — 1 H-t
The Court of Appeals acknowledged that petitioner properly preserved for federal review the claim that his counsel was ineffective in failing to call alibi witnesses. However, the Court of Appeals failed to address the merits of this claim. Nor did the court inquire whether, with respect to those claims that the court determined to be procedurally barred, petitioner could establish cause and prejudice and thus secure federal habeas review. I would vacate the judgment of the Court of Appeals and remand for further consideration of these matters. Because the Court’s remand goes significantly further, I dissent.
The rule the majority adopts applies only when there is an “ambiguity” concerning whether the last state court to write an opinion rejecting the applicant’s claims intended to rely on a procedural bar. Thus, the presence of an ambiguity on this point is a logical antecedent to the application of the Court’s rule. It is not entirely clear whether the majority treats the existence of an ambiguity in this case as a question determined adversely to respondent below (and which the Court is not inclined to revisit), or whether the majority intends to hold that the state court’s opinion was actually ambiguous. The former seems the more reasonable reading of the majority’s opinion, see ante, at 262, n. 8. Although I believe a fair interpretation of the state-court opinion would reveal no ambiguity, I will follow the majority’s lead and treat the case as if the opinion were ambiguous.
The majority explains that its new rule does not entail a presumption that state courts disobey their own procedural rules because “[t]he ‘plain statement’ rule relieves a federal court from having to determine whether in a given case, consistent with state law, the state court has chosen to forgive a procedural default.” Ante, at 265, n. 11. Of course, the majority’s reasoning assumes that in all cases of ambiguity there will always be an exception to the State’s procedural bar that is at least arguably applicable to the situation before the federal habeas court. Only if this is true will the majority’s new rule not be tantamount to a presumption that state courts disobey their own rules. The Court, however, does not explain why it is reasonable to make this assumption.
Our concern in Long with the importance of not rendering advisory opinions, 463 U. S., at 1041, is not pertinent in the present context. Procedural default rules differ significantly from substantive state-law grounds in that our decision to reach the underlying federal claim despite a procedural bar cannot result in our rendering an advisory opinion. See Henry v. Mississippi, 379 U. S. 443, 446-447 (1965).
Indeed, we have recognized that it is perfectly consistent with Michigan v. Long to conduct certain limited inquiries into state law. See, e. g., New York v. Class, 475 U. S. 106, 110 (1986); Ohio v. Johnson, 467 U. S. 493, 497-498, n. 7 (1984).
Although the majority states that a habeas petitioner may obtain i’elief by demonstrating that failure to consider the claim will result in a “ ‘fundamental miscarriage of justice,’ ” ante, at 262, it is clear that the majority’s reference relates solely to the narrow exception to the “cause” requirement we have recognized for the “extraordinary case, where a constitutional vi*281olation has probably resulted in the conviction of one who is actually innocent . . . .” Murray v. Carrier, 477 U. S. 478, 496 (1986). See ante, at 258, n. 2. Because the “fundamental miscarriage of justice” inquiry is a narrow exception to the cause-and-prejudice standard that is limited to claims of factual innocence, I prefer to avoid confusion by not treating it as a separate test.
The majority’s decision can only increase prisoner litigation and add to the burden on the federal courts in a class of cases that States likely have resolved correctly. It is well known “that prisoner actions occupy a disproportionate amount of the time and energy of the federal judiciary,” Rose v. Mitchell, 443 U. S. 545, 584 (1979) (Powell, J., concurring in judg*283ment), and that many of these petitions are entirely frivolous. Ibid.. In the year ending June 30, 1987, almost 10,000 habeas corpus petitions were filed by state prisoners. See 1987 Annual Report of the Director of the Administrative Office of the United States Courts 179. This monumental burden is unlikely to be alleviated by a rule that, on the dubious assumption that state courts do not enforce even obvious procedural bars, requires federal courts to resolve the merits of defaulted claims.