Kyzar v. Ryan, ___ F.3d ___, ___, 2015 WL 1061892 (9th Cir. Mar. 12, 2015) (habeas petitioners pro se filings before the Arizona trial court and the Arizona Court of Appeals fairly presented his sufficiency of the evidence claim, which was sufficient to exhaust his state remedies and avoid a procedural default: Although Kyzar did not cite In re Winship, 397 U.S. 358, 90 S.Ct. 1068, 25 L.Ed.2d 368 (1970), or Jackson for the proposition that the Due Process Clause of the Fourteenth Amendment protects him from being convicted unless the State proves every element of the charged offense beyond a reasonable doubt, the substance of Kyzar's claim was apparent from his attempt to articulate the legal elements for the crime of conviction and his explicit reference to due process. Indeed, Kyzar's citation to an Arizona Supreme Court case was entirely consistent with fair presentation of a Jackson claim, which necessarily turns on how crimes are defined under state law. [Citation omitted.] . . . Kyzar's pro se filing in the Arizona trial court plainly did enough to alert[ ] that court to the federal nature of [his] claim. Baldwin v. Reese, 541 U.S. 27, 29, 124 S.Ct. 1347, 158 L.Ed.2d 64 (2004).).
The court stated:
In order to fairly present an issue to a state court, a [habeas] petitioner must present the substance of his claim to the state courts, including a reference to a federal constitutional guarantee and a statement of facts that entitle the petitioner to relief. Gulbrandson v. Ryan, 738 F.3d 976, 992 (9th Cir.2013) (quoting Scott v. Schriro, 567 F.3d 573, 582 (9th Cir.2009)). [F]or the purposes of exhaustion, pro se petitions are held to a more lenient standard than counseled petitions. Sanders v. Ryder, 342 F.3d 991, 999 (9th Cir.2003) (citing Peterson v. Lampert, 319 F.3d 1153, 1159 (9th Cir.2003) (en banc)); see also Slack v. McDaniel, 529 U.S. 473, 487, 120 S.Ct. 1595, 146 L.Ed.2d 542 (2000) ([T]he complete exhaustion rule is not to trap the unwary pro se prisoner. (quoting Rose v. Lundy, 455 U.S. 509, 520, 102 S.Ct. 1198, 71 L.Ed.2d 379 (1982))).

(Id. at ___.)