IN A 1963 DECISION, THE SUPREME COURT HELD THAT A DEFENDANT COULD USE THE WRIT OF HABEAS CORPUS FOR FEDERAL REVIEW OF A STATE CONVICTION, REGARDLESS OF HIS FAILURE TO COMPLY WITH PROCEDURAL RULES, AS LONG AS HE HAD NOT DELIBERATELY BYPASSED THE STATE COURT PROCEDURES. THIS DECISION HAD THE EFFECT OF INCREASING FEDERAL COURT INTERFERENCE WITH STATE JUDICIAL OPERATIONS. A MORE RECENT TREND HAS BEEN TO LIMIT THE SCOPE OF THE 1963 DECISION, AND THE COURT HAS DEVELOPED A DIFFERENT STANDARD FOR HABEAS CONSIDERATION. IT HAS CONCLUDED THAT A FAILURE TO COMPLY WITH RULES OF CRIMINAL PROCEDURE CONSTITUTES A WAIVER OF COLLATERAL REVIEW UNLESS THE DEFENDANT CAN SHOW CAUSE FOR HIS NONCOMPLIANCE OR ACTUAL PREJUDICE RESULTING FROM COURT REFUSAL TO CONSIDER THE CLAIM. IN HIS OPINION ON ONE CASE, CHIEF JUSTICE BURGER STATED HABEAS REVIEW WAS ONLY PERMITTED IN ORDER TO CONSIDER WHETHER THE TRIAL COURT HAD PROPER JURISDICTION OR WHETHER THE STATE HAD ADHERED TO ITS OWN COURT PROCEDURES. THE WRIT WAS NOT CONSIDERED A MEANS BY WHICH ONE COURT OF GENERAL JURISDICTION COULD EXERCISE POSTCONVICTION REVIEW OVER THE JUDGMENT OF ANOTHER COURT OF LIKE AUTHORITY. THE FINDINGS OF SPECIFIC CASES AND THEIR CONTRIBUTIONS TO THIS TREND ARE DISCUSSED. (VDA)