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The doctrines regulating federal scrutiny of state criminal convictions have undergone substantial revision in the last few years.' Nonetheless, some principles seem to have remained constant. One such principle is the pattern of choice between federal and state preclusion standards on direct Supreme Court review and federal habeas corpus in cases in which federal constitutional rights have arguably been forfeited by waiver or procedural default.2 The preclusion standards at issue here are those that specify whether a federal reviewing court may address the merits of a constitutional claim not previously litigated or whether, in contrast, that claim has been "forfeited." To say that the pattern of choice has remained constant, however, is not to say that it is either simple or adequately explained in the cases or literature. On the contrary, most discussion focuses on one piece of the puzzle or another, without addressing how these jumbled pieces fit together.8 Yet

State Forfeiture Rules and Federal Review of State Criminal Convictions