Walker v. Martin
Issues
Whether a discretionary, case-by-case procedural bar for “untimely” habeas corpus petitions may be deemed “adequate” under the adequate state ground doctrine.
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.
Questions as Framed for the Court by the Parties
Under state law in California, a prisoner may be barred from collaterally attacking his conviction when the prisoner "substantially delayed" filing his habeas petition. In federal habeas corpus proceedings, is such a state law "inadequate" to support a procedural bar because (1) the federal court believes that the rule is vague and (2) the state failed to prove that its courts "consistently" exercised their discretion when applying the rule in other cases?
All California courts, both state and federal, have original jurisdiction to hear habeas corpus petitions. See Brief for Respondent, Charles Martin at 7. However, if any court finds that a petitioner’s claims are procedurally barred, it may deny the claim with a “summary denial,” which
Edited by
Additional Resources
· California Petition for Writ of Habeas Corpus
· Columbia Law Review, Catherine Struve, Direct and Collateral Federal Court Review of the Adequacy of State Procedural Rules
· Federalist Society, Kent Scheidegger and Tom Gede: The Inadequate Jurisprudence of Adequate State Grounds
· American University Law Review, Cynthia L. Fountaine: Article III and the Adequate Independent Grounds Doctrine