Reasons are reviewed for why it is more difficult today than it was a decade ago for a State prisoner to persuade a Federal court to review the propriety of his State court conviction or sentence, and the new relationship between Federal and State courts is described. Criticisms of Federal court review of State court convictions are reported, and attention focuses on judges' concerns about the dramatic growth in the number of prisoner conditions-of-confinement cases. Congressional, judicial, and legislative efforts to limit Federal habeas corpus review are explored, as are Department of Justice proposals. If adopted the author believes these proposals would effectively close access to Federal habeas corpus to State prisoners who claim that their convictions or sentences resulted from State processes that violated the U.S. Constitution. Rules governing Section 2254 cases in the U.S. district courts are delineated, and three U.S. Supreme Court cases that have had a significant impact on habeas corpus procedure are discussed: Engle v. Isaac, Rose v. Lundy, and Sumner v. Mata. Finally, the Court's decision in Sandstrom v. Montana is discussed, and the need for improved procedures for reviewing habeas corpus petitions is noted. Included are 85 references.