court.” Id. at 510, 102 S.Ct. 1198. Although the language of Rose seemed to allow only the above three options, this court, in a footnote in Neuschafer v. Whitley, 860 F.2d 1470 (9th Cir.1988), suggested an alternative procedure, that of stay- and-abeyance: “When a petitioner has not exhausted his state remedies before filing a federal habeas petition, a district court may hold the federal petition in abeyance, issue a stay of execution, and allow the petitioner an opportunity to exhaust his state remedies.” Id. at 1472 n. 1. Subsequent Ninth Circuit cases, however, rejected the stay-and-abeyance procedure offered in Neuschafer, holding it inconsistent with Rose. Taylor, 134 F.3d at 985; see also Calderon v. United States District Court (Gordon), 107 F.3d 756, 760 (9th Cir.1997) (<HOLDING>); Greenawalt v. Stewart, 105 F.3d 1268, 1274
holding that automatic reversal rule applies in habeas petitions holding that the district court erred when it relied on neuschafer for the proposition that dismissal of mixed habeas petitions is not the rule in the ninth circuit  holding that when the district court dismissed rather than transferred a case not within its jurisdiction and a party appealed that dismissal the circuit court could consider only the propriety of the dismissal on appeal and determining that the circuit court lacked jurisdiction on appeal to consider the merits of the action holding that the ninth circuit erred by failing to defer to the bias reasonable interpretation of the ina holding that district court error was not clear error because no prior ninth circuit authority prohibited the course taken by the district court