Read the following excerpt from a US court opinion:
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v. Madigan, Cir.) (same), cert. denied, — U.S. -, 124 S.Ct. 531, 157 L.Ed.2d 412 (2003). Nonetheless, the court in Theodoropoulos II also recognized an exceedingly narrow exception. It stated that although “as a general rule, courts are required to strictly enforce statutory exhaustion requirements[,]” there are “some limited circumstances in which an exception to the general rule might apply.” 358 F.3d at 172-73. We invoke the narrow leeway afforded by Theodoropoulos II and hold that in light of the unusual facts of Pichardo’s case, an exception is necessary to prevent manifest injustice. Courts have historically interpreted procedural rules to prevent a fundamental miscarriage of justice. See, e.g., Coleman v. Thompson, 501 U.S. 722, 750, 111 S.Ct. 2546, 115 L.Ed.2d 640 (1991) ; McCleskey v. Zant, 499 U.S. 467, 494, 111
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What is the most suitable continuation to the opinion? Your options are:
A. holding that in the case of state procedural default a federal habeas review of the claims is barred unless the prisoner can demonstrate among other things that failure to consider the claims will result in a fundamental miscarriage of justice
B. holding that failure to consider an improper jury instruction would constitute a miscarriage of justice
C. holding that federal review of claims is barred where those claims have been defaulted in state court pursuant to an independent and adequate state procedural rule unless the petitioner can demonstrate cause and prejudice
D. holding that courts may only review claims for fundamental miscarriage of justice
E. holding that a prisoners failure to pursue an appeal in state court is a procedural bar to federal habeas relief unless the petitioner shows both cause for failing to bring the state claim  and actual prejudice from the failure to consider his federal claims
Reply with [A, B, C, D, E] only.