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In Rose v. Lundy 455 U.S. 509 (1982) the supreme court adopted the total exhaustion doctrine. Section 2254, does not directly address the problem of mixed petitions. The exhaustion doctrine is principally designed to protect the state courts' role in the enforcement of federal law and prevent disruption of state judicial proceedings. A rigorously enforced total exhaustion rule encourages state prisoners to seek full relief first from the state courts, thus giving those courts the first opportunity to review all claims of constitutional error. As the number of prisoners who exhaust all of their federal claims increases, state courts may become increasingly familiar ...