Baldwin v. Reese, 541 U.S. __, 124 S.Ct. 1347 (March 2, 2004) (ineffective assistance of counsel claim not "fairly presented" to state court where briefs did not complain that ineffective assistance violated federal law; state high courts not required to read lower appellate opinions before deciding whether to grant hearing; state high courts should be able to rely exclusively on briefs to alert them to issues presented): "A litigant wishing to raise a federal issue can easily indicate the federal law basis for his claim in a state court petition or brief, for example, by citing in conjunction with the claim the federal source of law on which he relies or a case deciding such a claim on federal grounds, or by simply labeling the claim 'federal.'"