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It may be, however, that the recent attention to the issue of innocence detracts from this fact.
"I think that the issue of innocence is what has triggered much of this concern," he said.
"The issue of innocence and guilt is something that I've always looked at very closely," said Cynthia Tauss, who has studied criminal justice.
Even in cases where the trial was considered deficient, the prisoner would be allowed to appeal to federal court only once, unless the petition involved issues of innocence or guilt.
In Mr. Beardslee's case, though, there was no issue of innocence: he confessed to killing two women in California and one in Missouri.
In 2007, Jonathan Jackson took on the issues of innocence and juvenile justice as national spokesman for the RainbowPUSH Coalition.
A16 THE ISSUE OF INNOCENCE A Texas inmate won a stay of execution so his lawyers could argue that his constitutional rights were violated simply because he is innocent, an issue never fully addressed by the Supreme Court.