## Facts

- Charles W. Martin was convicted in California of murder and robbery and sentenced to life imprisonment without parole.
- After the California Supreme Court denied Martin’s first state habeas petition, he filed a federal habeas petition.
- The federal district court stayed the federal case to allow Martin to return to state court to exhaust new ineffective-assistance-of-counsel claims.
- Martin filed a second habeas petition in the California Supreme Court asserting those new claims nearly five years after his conviction became final, offering no explanation for the delay.
- The California Supreme Court summarily denied the second petition with citations signaling dismissal as untimely under California’s timeliness doctrine.
- On return to federal court, the district court dismissed the belated claims as procedurally defaulted based on California’s timeliness rule.
- The Ninth Circuit held California’s indeterminate timeliness rule inadequate to bar federal habeas review and directed further adequacy analysis; the district court again found the rule adequate, but the Ninth Circuit again rejected adequacy.

## Issues

1. Whether California’s state habeas timeliness requirement—expressed as filing “as promptly as the circumstances allow” and without “substantial delay”—is an independent and adequate state procedural ground that bars federal habeas review of claims rejected as untimely.

## Decision

- The Supreme Court unanimously reversed the Ninth Circuit.
- The Court held that California’s timeliness rule is an independent and adequate state procedural ground.
- Because Martin’s second state habeas petition was denied as untimely, federal habeas review of those claims was barred absent an applicable exception to procedural default.

## Legal Principles

- Federal habeas courts generally may not review claims rejected by a state court on a state procedural ground that is both (a) independent of federal law and (b) adequate, meaning firmly established and regularly followed.
- A state procedural rule can be “adequate” even if framed as a general standard rather than a fixed deadline; standards based on reasonableness or diligence may qualify when articulated and regularly applied in state practice.
- A state ground is “independent” when its application does not turn on the resolution of federal constitutional questions.
- A state court’s discretionary ability to bypass a procedural bar and deny on the merits does not alone defeat adequacy if the procedural bar is regularly enforced.

## Conclusion

The Court held that California’s judge-made habeas timeliness standard, though indeterminate, is sufficiently established and regularly applied to constitute an independent and adequate state ground, thereby precluding federal habeas review of claims the California Supreme Court rejected as untimely.


Walker v. Martin, 562 U.S. 307 (2011)