King v. Lamarque, ___ F.3d ___ (9th Cir. Jul. 26, 2006) (simply contesting the adequacy of a state rule is sufficient to meet the petitioner's burden, under Bennett v. Mueller, 322 F.3d 573 (9th Cir. 2003), if the court has previously found the rule to be too ambiguous to bar federal review during the applicable time period).
http://caselaw.lp.findlaw.com/data2/circs/9th/0515757p.pdf