1.   So the only issue before me is actual innocence of first-degree murder.

2.   And actual innocence is the least effective argument to make for a new trial because it is so difficult to prove.

3.   Application of the stricter Sawyer standard would give insufficient weight to the correspondingly greater injustice that is implicated by an actual innocence claim.

4.   As used in Carrier, actual innocence is closely related to the definition set forth by this Court in Sawyer.

5.   Because such evidence is obviously unavailable in the vast majority of cases, claims of actual innocence are rarely successful.

6.   A habeas court reviewing a claim of actual innocence does not write on a clean slate.

7.   In addition to convictions that have been overturned, there have been several instances in recent years in which the actual innocence of defendants has been established.

8.   In the years following Kuhlmann and Carrier, we did not expound further on the actual innocence exception.

9.   Of greater importance, the individual interest in avoiding injustice is most compelling in the context of actual innocence.

10.   Sure, many of the executed claimed actual innocence up to the end.