Here, C.P.L. § 440.10(3)(c) — the rule that § 440 courts may dismiss claims not raised in prior § 440 motions — is a "firmly established and regularly followed" rule. See, e.g., People v. Dover, 294 A.D.2d 594, 596, 743 N.Y.S.2d 501, 503 (2d Dep't 2002) (dismissing under, inter alia, C.P.L. § 440.10(3)(c) because defendant could have raised ineffective counsel claim in prior § 440 motion); People v. Dominguez, 257 A.D.2d 511, 512, 685 N.Y.S.2d 14, 15 (1st Dep't) ("The court properly denied defendant's CPL 440.10 motion alleging ineffective assistance of counsel, on the ground that defendant had filed a previous CPL 440.10 motion and could have raised the issues set forth in the second application on the first but failed to do so (CPL 440.10 [3] [c])."), appeal denied, 93 N.Y.2d 872, 689 N.Y.S.2d 434 (1999). Moreover, district courts in this Circuit have consistently held that C.P.L. § 440.10(3)(c) constitutes an adequate and independent state ground barring habeas review.