Villafuerte v. Lewis, 75 F.3d 1330, 1335 (9th Cir.1996), analogous to “plain error” review in federal court. The Arizona doctrine preserves for appeal issues that “may be so important that overriding considerations concerning the integrity of the system will excuse a party’s failure to raise the issue in the trial court.” State v. Gendron, 168 Ariz. 153, 812 P.2d 626, 628 (1991). Although the Arizona Supreme Court has noted that fundamental error “usually, if not always, involves the loss of federal constitutional rights,” id., Castillo’s mere assertion of fundamental error does not mean he asserted a federal constitutional claim; claims subject to fundamental error review may consist entirely of assertions under Arizona law. See Johnson v. Lewis, 929 F.2d 460, 462 (9th Cir.1991) (<HOLDING>). Thus, an argument of “fundamental error”
holding that a claim is considered exhausted by arizonas fundamental error review if it was explicitly noted in the briefs presented to the state appellate court or the state court mentions it is considering the claim sua sponte holding that the reference to any court encompasses both state and federal courts holding that lack of appellate jurisdiction is fundamental error holding a party failed to preserve error on its constitutional due process argument concerning notice when they did not cite any state or federal constitutional provision to the trial court or otherwise explain how lack of notice violated their constitutional rights holding that when neither the petitioners state court briefs nor the state courts decision made any reference to any federal constitutional claim or cited any federal constitutional cases the lack of fundamental error found by the state court was a lack of fundamental error under arizonas state constitution