On February 23, 2011, the Supreme Court decided Walker v. Martin, No. 09-996, holding that California's "reasonableness" standard governing the timeliness of requests for post-conviction relief qualifies as an independent and adequate state procedural ground for barring federal habeas corpus relief.
Most states have firm time limits for seeking post-conviction habeas corpus relief. California courts, however, apply a "reasonableness" standard to determine whether a habeas petition is timely.
Charles Martin was convicted in 1997. The California Supreme Court denied his habeas petition in 1999. Martin filed a second habeas petition in 2002, claiming ineffective assistance of counsel for the first time. Martin did not explain why he failed to assert this claim earlier, and the California Supreme Court denied his petition for "failure to file as promptly as the circumstances allow."
Martin then sought habeas relief in federal court. The District Court denied Martin's petition as procedurally barred. The Ninth Circuit remanded, directing the District Court to determine whether the timeliness bar was an adequate ground for barring federal habeas relief. The District Court again denied Martin's petition, finding that the California procedural bar was "clearly defined, well established and consistently applied." The Ninth Circuit reversed.
In a unanimous decision, the Supreme Court reversed, relying largely on its decision in Beard v. Kindler, 558 U.S. ___ (2009), in which the Court held that to qualify as "adequate," a state procedural bar must be "firmly established and regularly followed." The Court also held in Beard that a "discretionary state procedural rule can serve as an adequate ground to bar federal habeas review" and "can be ‘firmly established' and ‘regularly followed' even if the appropriate exercise of discretion may permit consideration of a federal claim in some cases but not others." Relying on Kindler, the Court rejected Martin's argument that the California timeliness rule was "too vague to be regarded as ‘firmly established,'" noting that time limitations need not be stated in "precise, numerical terms." The Court also observed that the rule was "regularly followed" because the California Supreme Court "summarily denies hundreds of habeas petition by citing Clark and Robbins" every year. The Court was careful to note that Martin did not contend that the California Supreme Court "exercised its discretion in a surprising or unfair manner," or that the state rule discriminated against claimants seeking to vindicate federal rights.
Justice Ginsberg delivered the opinion for a unanimous Court.