Oral argument: Nov. 29, 2010
Appealed from: United States Court of Appeals for the Ninth Circuit (Oct. 6, 2009)
HABEAS CORPUS, PROCEDURAL BAR, ADEQUATE STATE GROUNDS DOCTRINE, TIMELINESS
Charles Martin is serving life imprisonment for the robbery and first-degree murder of Charles Stapleton. After exhausting his direct appeals, Martin filed a petition for habeas corpus in California state court, alleging that his trial counsel was ineffective. The California Supreme Court eventually dismissed the petition under the state’s “timeliness” rule, which bars claims filed after “substantial delay.” Martin then filed a habeas corpus claim in federal court on similar grounds. The federal district court found that the state timeliness grounds were “adequate” for dismissal of the federal case. Under the adequate state grounds doctrine, a federal court will not review the decision of a state court if the federal court’s decision would have no impact on the case. The Ninth Circuit reversed, finding that the state had failed to prove that California’s timeliness rule was sufficiently clear and consistently applied so as to be an adequate state bar. Martin argues that the Ninth Circuit was correct in its ruling, while Petitioner James Walker counters that the rule is indeed consistently applied. If the Supreme Court finds the rule adequate, this will likely increase denials of federal habeas corpus petitions; if the rule is not adequate, however, California may be required to use a more precise standard in determining what constitutes an untimely petition.