dissenting:
The majority, citing Harris v. Reed as authority, 489 U.S. 255, 109 S.Ct. 1038, 103 L.Ed.2d 308 (1989), in effect holds that a federal habeas court may review a state court decision that does not include a plain statement that it relies on state law, even *865though the state court decision does not in any way indicate that its decision is based on federal law. Such a requirement dramatically expands the scope of federal habeas review of state court judgments in disregard of the Supreme Court’s concern for comity with the state courts and the finality of state court judgments expressed in Wainwright v. Sykes, 433 U.S. 72, 87, 97 S.Ct. 2497, 2506-07, 53 L.Ed.2d 594 (1977). Because the majority thoroughly misapplies the Harris v. Reed plain statement rule, I respectfully dissent.
Under Harris, a federal habeas court may review a petition raising a federal claim despite a state procedural bar if the state court opinion is ambiguous on the question of whether the state court rejected the federal claim on the basis of its understanding of federal law or on the state procedural bar. Harris v. Reed, 489 U.S. 255, 109 S.Ct. 1038, 1042, 103 L.Ed.2d 308 (1989). The state court can remove the ambiguity and prevent federal review only by a plain statement that it relied upon an adequate and independent state ground. Id. In the instant case, the Mississippi Supreme Court did not base its rejection of Young’s federal due process claim on its interpretation of federal law, nor was its discussion of state law intertwined with its interpretation of federal law. Because the state court decision was not ambiguous for purposes of Harris v. Reed, the majority errs in reaching the merits of Young’s federal due process claim absent a showing of cause for Young’s failure to comply with the state procedural rule and actual prejudice resulting from imposition of the procedural default. Wainwright v. Sykes, 433 U.S. 72, 87, 97 S.Ct. 2497, 2506-07, 53 L.Ed.2d 594 (1977).
In Harris, the Illinois Appellate Court found that under state law the petitioner waived state post-conviction review of his claim that he received ineffective assistance of counsel because he failed to raise that claim on direct appeal. The Illinois court went on, however, to consider and reject petitioner’s ineffective assistance claim on the merits. Harris v. Reed, 109 S.Ct. at 1040.
The Illinois court did not clearly state that its rejection of the petitioner’s ineffective assistance claim on the merits was an alternative rather than the sole basis for its decision.1 Under these circumstances, the Supreme Court found that the state court decision was ambiguous on the question of whether it based its decision on the state court’s interpretation of federal law concerning ineffective assistance of counsel or whether it based its decision on the state procedural default.2 The Supreme Court concluded, therefore, that the federal habeas court was not precluded from considering the petitioner’s federal claim because the final state court to review the claim had not included a clear and express statement that it was relying on an adequate and independent state procedural ground. Id. at 1045.
Neither the rationale, the plain language, nor the specific facts in Harris require a “plain statement” when the state court did not rely on federal law to deny the petitioner’s claim and the only question that might be considered ambiguous is the precise state grounds upon which the state court based its decision.3 Under such circum*866stances, we may review the federal claim without a showing of cause and prejudice only if the state procedural ground was not adequate to support the state court’s judgment.4
While the Mississippi Supreme Court’s discussion is hardly a model of clarity, it is not ambiguous. In order for language to be ambiguous, not only must its meaning be unclear, but its interpretation must be doubtful to a person of competent skill and understanding.5 The Mississippi Supreme Court rejected Young’s federal due process claim that Mrs. Hoard based her in-court identification on an improperly suggestive pre-trial identification because it found that Young’s attorney did not object to Mrs. Hoard’s in-court identification on that basis. Young’s objection, the Mississippi Supreme Court found, rested solely on the grounds that Mrs. Hoard’s in-court identification came after a pre-trial photographic identification, a claim that does not raise a federal due process issue.6 The Mississippi Supreme Court then upheld the trial court’s *867decision not to strike Mrs. Hoard’s identification, or grant a new trial, without discussing Young’s claim that the pre-trial procedure was improperly suggestive.7
The conclusion appears inescapable that the Mississippi Supreme Court rejected Young’s claim because his attorney procedurally defaulted by failing to properly object. In fact, this was precisely our finding in our earlier opinion.8 The Mississippi Supreme Court’s failure to state that it based its decision on its contemporaneous objection rule may make the opinion vague.9 It does not make the opinion ambiguous, however, because the opinion is not reasonably susceptible to more than one interpretation.
If the Mississippi Supreme Court’s opinion can be considered ambiguous at all, it is ambiguous only on the question of exactly what state procedural ground the court relied upon in not reaching Young’s federal due process claim. Such ambiguity is not relevant to a Harris v. Reed analysis. The relevant ambiguity for purposes of the adequate and independent state grounds doctrine is whether the state court relied on federal or state law. If the Mississippi Supreme Court had found against Young on the merits of his claim and also found that the claim was proeedurally barred, the opinion would be ambiguous for purposes of the adequate and independent state grounds doctrine absent a plain statement that the state court relied upon the procedural bar. The Illinois appellate court’s opinion in Harris was ambiguous for just this reason. If the Mississippi Supreme Court had relied upon its state constitution’s due process provisions, but had cited federal due process cases, the opinion would have been ambiguous because the state court’s interpretation of its law was intertwined with its understanding of federal law. Precisely this kind of ambiguity spurred the Supreme Court to require a plain statement in Michigan v. Long.
The facts in our case, however, indicate no such ambiguity. The Mississippi Su*868preme Court clearly did not reach the merits of Young’s due process claim. Nor did the two state court opinions cited by the Mississippi Supreme Court indicate that its understanding of state law was intertwined with its interpretation of federal law. The Mississippi Supreme Court cited those cases for the proposition that the credibility of a witness is for the jury to determine when an in-court identification follows a pre-trial photographic identification. They were not cited as authority to reject Young's claim that the pre-trial identification was improperly suggestive. Under these circumstances, the Mississippi Supreme Court’s decision, even if it could be considered ambiguous, is not ambiguous for purposes of Harris v. Reed.
*867BY MR. FARESE [Young’s attorney]: Comes now the defendant and respectfully moves the Court to strike out all the testimony of the witness Mrs. Hoard on the grounds that Mrs. Hoard made an alleged identification of the defendant from the photograph before she came into Court and made an in-court identification. We move that the Court order all her testimony stricken, and move for a mistrial also at this point.
******
BY JUDGE BIGGERS: The Court is of the opinion that it is a question for the jury to determine what weight they wish to give this identification the way the question was framed to the witness, as the Court recalls, it was not based on whether she saw and identified a picture of this defendant some time after the robbery, but whether or not she saw, yesterday, the man who robbed her, in the courtroom. She pointed out she did. It is not clear in the record that this identification was based on having seen a picture; maybe she did, as she testified, point him out in a picture, the way the question was framed. She identified the man today as the man who robbed her, based on the identification.
*868The Supreme Court in recent years has narrowed the scope of federal habeas review based on principles of comity and respect for the finality of state court judgments. See Stone v. Powell, 428 U.S. 465, 96 S.Ct. 3037, 49 L.Ed.2d 1067 (1976); Wainwright v. Sykes, 433 U.S. 72, 97 S.Ct. 2497, 53 L.Ed.2d 594 (1977). The majority’s opinion would require a state court to include a “plain statement” that it bases its decision on an adequate and independent state law ground even when the state court did not rely on federal law in making its decision. Such a requirement dramatically expands the scope of federal habeas review of state court judgments and disregards the Supreme Court’s rationale for its decisions in Stone v. Powell, 428 U.S. 465, 96 S.Ct. 3037, 49 L.Ed.2d 1067 (1976), and Wainwright v. Sykes, 433 U.S. 72, 87, 97 S.Ct. 2497, 2506-07, 53 L.Ed.2d 594 (1977).
Even assuming, arguendo, that we may review Young’s due process claim because the Mississippi Supreme Court failed to include a plain statement that it was relying on an adequate and independent state law ground, the majority erred in granting the writ without discussing the merits of the state’s contention that Young’s claim was procedurally barred. The majority does not decide that the Mississippi Supreme Court erred in concluding that Young failed properly to object to Mrs. Hoard’s in-court identification, and it does not decide that a proper objection was not required. Nor did the Mississippi Supreme Court waive the procedural bar.10 The majority opinion provides no reason, therefore, to believe that the Mississippi Supreme Court was not justified in failing to reach the merits of Young’s claim. Nevertheless, the majority ignores the state procedural bar. Apparently, the majority construes Harris as giving this court carte blanche to disregard adequate state law grounds if the state court fails to include a plain statement that it relied on state law. The Supreme Court, we observe, has never assumed such power on entertaining a direct appeal from an ambiguous state court judgment.11
Because the Mississippi Supreme Court’s opinion clearly did not rely on federal law, and the state law ground was adequate to support the Mississippi Supreme Court’s judgment, the adequate and independent *869state grounds doctrine 12 prevents our review of Young’s claim that the pre-trial photographic identification was improperly suggestive absent a showing of cause and actual prejudice for Young’s failure to comply with Mississippi’s contemporaneous objection rule. Wainwright v. Sykes, 433 U.S. 72, 87, 97 S.Ct. 2497, 2506-07, 53 L.Ed.2d 594 (1977). Because Young failed to demonstrate cause for his failure to comply with Mississippi’s procedural rules, the majority should not have reached the merits of his claim.13
The majority’s requirement that a state court provide a clear and express statement that it relied on adequate and independent state grounds, even though the state court opinion is not ambiguous on this question, expands the scope of federal habeas corpus review. Nor does Harris v. Reed’s plain statement rule allow us simply to ignore state law grounds adequate to support its judgment. For both these reasons, I respectfully dissent. The bottom line is that we got this case right the first time, and there is no reason to revisit it and change the result of the first panel.
. The ambiguity in Harris arose because "[t]he state court 'did not appear to make two rulings in the alternative, but rather to note a procedural default and then ignore it, reaching the merits instead.’ ’’ Harris, 109 S.Ct. at 1041, quoting the district court’s decision, 608 F.Supp. 1369, 1378 (N.D.Ill.1985). In our case, the Mississippi Supreme Court never reached the merits of Young’s due process claim.
. Seventh Circuit precedent established that if "the state court ignores the procedural default and addresses the claim on its merits, a federal court is not precluded from reaching the merits of the claim in a petition for habeas corpus." Under such circumstances, the Seventh Circuit deemed the decision on the merits to waive the state procedural bar. Harris v. Reed, 822 F.2d 684 (1987), rev'd by, 489 U.S. 255, 109 S.Ct. 1038, 103 L.Ed.2d 308 (1989).
.In Harris, the Supreme Court noted that the state court's invocation of a procedural default arguably would have prevented review even without a plain statement that it relied on an adequate and independent state ground if the state court never reached the federal claim. Unlike the instant case, however, the state court in Harris
*866clearly went on to reject the federal claim on the merits. As a result, the reference to state law in the state court's opinion is insufficient to demonstrate clearly whether the court intended to invoke waiver as an alternative ground. It is precisely with regard to such an ambiguous reference to state law in the context of clear reliance on federal law that Long permits federal review of the federal issue.
Harris v. Reed, 109 S.Ct. at 1045, n. 13 (emphasis added).
. We do not mean to imply that any vague reference to a state procedural rule will bar federal habeas review if the state court fails to discuss the federal issue. The state ground must be an "adequate" as well as an “independent” state law ground. The Supreme Court has found state procedural rules inadequate to prevent review of the defendant’s federal claim in a variety of circumstances. For example, the Supreme Court has found a state procedural bar inadequate when the procedure itself violates the Fourteenth Amendment’s due process clause. See Reece v. Georgia, 350 U.S. 85, 76 S.Ct. 167, 100 L.Ed. 77 (1955) (state rule requiring that objections to the composition of grand juries be made by criminal defendants before their indictment did not bar Supreme Court review of a claim made by a semi-illiterate defendant of low mentality for whom counsel had not been appointed until after he had been indicted). Nor does a state procedural rule preclude review if the procedure has not been strictly followed, or if the result in a particular case is inconsistent with past practice. See James v. Kentucky, 466 U.S. 341, 104 S.Ct. 1830, 80 L.Ed.2d 346 (1984) (Fact that defendant requested only an "admonition” rather than "instruction” did not preclude Supreme Court review of defendant’s claim that the jury had not been properly charged to ignore defendant’s failure to testify because distinction between "admonition” and “instruction” had not been applied consistently in the past).
. BLACK’S LAW DICTIONARY 41 (5th ed., abridged, 1983) defines ambiguity as
Doubtfulness; doubleness of meaning. Duplicity, indistinctness, or uncertainty of meaning of an expression used in a written instrument____ Ambiguity of language is to be distinguished from unintelligibility and inaccuracy, for words cannot be said to be ambiguous unless their signification seems doubtful and uncertain to persons of competent skill and knowledge to understand them.
Ambiguity must be distinguished from vagueness:
It is unfortunate that many lawyers persist in using the word ambiguity to include vagueness____ Whereas ambiguity in its classical sense refers to equivocation, vagueness refers to the degree to which, independently of equivocation, language is uncertain in its respective applications to a number of particulars. Whereas the uncertainty of ambiguity is central, with an ‘either-or’ challenge, the uncertainty of vagueness lies in marginal questions of degree.
R. Dickerson, The Interpretation of Statutes 48-49 (1975). Although the Mississippi Supreme Court’s decision may be vague, its signification does not seem doubtful to a person of competent skill and knowledge.
.After examining Young’s objection, the Mississippi Supreme Court concluded:
Young’s motion to strike the testimony and for a mistrial, dealt not with an allegation that the in-court identification was gained as the result of a suggestive or improper pre-trial identification procedure, but was on the sole basis that the witness’ in-court identification came after a pre-trial photographic identification. Under this circumstance the lower court did not err in ruling the credibility of Mrs. Hoard’s identification was for the jury to weigh. McNeal v. State, 405 So.2d 90 (Miss. 1981). We reiterate as we stated in Chambers v. State, 402 So.2d 344, 347 (Miss. 1981), "We are content to rely upon the good sense and judgment of juries, for evidence with some element of untrustworthiness is customary grist for the jury mill. Juries are not so susceptible that they cannot measure intelligently the weight of identification testimony that has some questionable feature.”
Young v. State, 420 So.2d 1055, 1059 (Miss. 1982).
. The day following Mrs. Hoard’s in-court identification, Young’s attorney objected to the trial court's admission of Mrs. Hoard's in-court identification as follows:
. In our earlier opinion, we found:
Although the Mississippi Supreme Court did not expressly state that Young's motion for new trial came too late, that is obviously implicit in its holding that Young procedurally defaulted, and in its refusal, for that reason, to rule on the merits of his claim of improperly suggestive pre-trial identification. As indicated in the [Mississippi Supreme] Court’s opinion, it clearly determined that Young was afforded ample opportunity to go into the matter during trial.... Likewise, ... the state argued in its brief to the Mississippi Supreme Court that Young had waived the claim by not raising it until after verdict. Further, the law of Mississippi is clear that, where the matter could have been raised during trial, raising it for the first time by motion after verdict is too late.... In these circumstances, we treat the Mississippi Supreme Court’s opinion as if it had expressly stated that raising the matter for the first time by motion for new trial was, under these facts, too late to preserve it.
Young v. Herring, 777 F.2d 198, 204 n. 11 (1985). The majority expresses no disagreement with this finding.
.MISS.CODE ANN. § 99-39-21(1) states:
Failure by a prisoner to raise objections, defenses, claims, questions, issues or errors whether in fact or law which were capable of determination at trial and/or on direct appeal, regardless of whether such are based on the laws and the Constitution of the State of Mississippi or of the United States, shall constitute a waiver thereof and shall be proeedurally barred, but the court may upon a showing of cause and actual prejudice grant relief from the waiver.
. In Harris v. Reed, the Seventh Circuit considered whether the state court waived the procedural error by addressing the petitioner's claim on the merits. Harris v. Reed, 822 F.2d 684 (7th Cir.1987), rev’d by, 489 U.S. 255, 109 S.Ct. 1038, 103 L.Ed.2d 308 (1989). No such waiver, however, can be inferred in the instant case. The Mississippi Supreme Court did not address the merits of Young’s claim and indicated that it believed that Young’s claim had been foreclosed. The failure to include a plain statement, therefore, can hardly be construed as waiving Mississippi’s procedural bar.
. Under the Michigan v. Long plain statement rule, the state court on remand from the United States Supreme Court may conclude that it based its decision on state law and ignore the Supreme Court’s analysis of federal law. Such a conclusion, in effect, makes the Supreme Court’s opinion merely advisory. See e.g., People v. Class, 67 N.Y.2d 431, 433, 494 N.E.2d 444, 445, 503 N.Y.S.2d 313, 314 (1986) (The Supreme Court reviewed a New York decision because of a lack of a plain statement that it relied upon slate law. On remand, the Court of Appeals of New York reinstated its earlier judgment, stating that it found a violation of its state constitution.). See also, Comment, Michigan v. Long: The Inadequacies of Independent and Adequate State Grounds, 42 U.Miami L.Rev. 159, 172 (1987). Under the majority’s opinion in the instant case, however, the state has no opportunity to establish that its decision was based on state law, although the majority finds only that the state court’s opinion is ambiguous on this point.
. In our former opinion in this case, we observed that the state grounds were obviously adequate and independent. We stated:
Plainly, the procedural ground in question was a state ground, and was "independent” in the Sykes sense, that is independent of the merits, as the Mississippi Supreme Court never reached the merits because of the procedural default____ Plainly, the requirement for a correct contemporaneous objection is an "adequate” state ground. We have upheld similar requirements many times.
Young v. Herring, 777 F.2d at 203 n. 9.
. As we found in our former opinion in this case, Young could not have been expected to have objected that the pre-trial identification was improperly suggestive immediately after Mrs. Hoard testified. Neither Young nor the trial judge had yet seen the photographs upon which Mrs. Hoard based her pre-trial identification. Young did not make any further objections to Mrs. Hoard’s identification, however, until after the jury returned a guilty verdict. Once Young’s attorney had a chance to review the photographs, he no longer had good cause for failing to object. Young v. Herring, 777 F.2d 198, 202 (5th Cir.1985). The Mississippi Supreme Court stated that "Young was provided all of the photographs prior to the presentation of his version of the case,” which enabled him "to fully examine the entire identification procedure in his case-in-chief.” Young v. State, 420 So.2d 1055, 1060 (Miss.1982). Because Young cannot demonstrate cause for his failure to comply with Mississippi's contemporaneous objection rule, I do not reach the question of whether Mississippi’s application of that rule prejudiced him.