Walker v. Martin

PETITIONER: James Walker, Warden, et al.
RESPONDENT: Charles W. Martin
LOCATION: U.S. Court of Appeals for the Ninth Circuit

DOCKET NO.: 09-996
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 562 US (2011)
GRANTED: Jun 21, 2010
ARGUED: Nov 29, 2010
DECIDED: Feb 23, 2011

ADVOCATES:
Michael B. Bigelow - for the respondent (appointed by the Court)
Michael R Bigelow - on behalf of the respondent
Todd Marshall - for the petitioner

Facts of the case

A California state court convicted Charles Martin of robbery and murder and sentenced him to life in prison without the possibility of parole. Subsequently, Mr. Martin filed a round of habeas petitions in state court – all of which were denied. He then raised several new claims in petitions for federal habeas relief in a California federal district court. The court denied to examine the claims because they were not yet exhausted in state court. After Mr. Martin exhausted these last claims in state court, he returned to federal court for federal habeas corpus relief. The district court again denied the petition relying on California's statute of limitations for filing state habeas corpus petitions.

On appeal, the U.S. Court of Appeals for the Ninth Circuit reversed the district court, holding that California's statute of limitations could not operate as an independent and adequate state ground to bar federal habeas corpus review. The court reasoned that California's statute of limitations was not sufficiently defined, nor consistently applied such that it could bar Mr. Martin's petition.

Question

In a federal habeas corpus proceeding, is a state law barring a prisoner from attacking his conviction an insufficient procedural bar because the federal court thinks the rule is (1) vague and (2) the state failed to prove that the bar is consistently applied?

Media for Walker v. Martin

Audio Transcription for Oral Argument - November 29, 2010 in Walker v. Martin

Audio Transcription for Opinion Announcement - February 23, 2011 in Walker v. Martin

Ruth Bader Ginsburg:

This case concerns California's time limitation on applications for postconviction relief.

The question presented: “Does California's requirement that habeas corpus petitions be filed as promptly as possible qualify as an independent State ground for denying relief adequate to bar a subsequent application for the same relief in federal court?

Unlike most states, California does not employ fixed statutory deadlines to determine the timeliness of a state prisoner's petition for habeas corpus.

Instead, California directs petitioners to file known claims without substantial delay.

Petitioners are further instructed to state when they first learned of the claims they are asserting and to explain why they did not advance those claims sooner.

Claims not presented as promptly as the circumstances allow may be denied as untimely.

California courts signal that a habeas petition is denied as time barred by citing the California Supreme Court's controlling decisions, In re Clark and In re Robbins.

But denial of a petition for undue delay is a may, not a must.

A California court has discretion to pass over the question whether a petition was filed too late and simply deny the petition for want of merit.

Petitioner below, respondent here, Charles W. Martin presented claims for postconviction relief, allegations that his counsel had provided ineffective assistance in a habeas petition filed in the California Supreme Court, nearly five years after his conviction became final.

Habeas petitioners in California can file directly in the Supreme Court.

They need not climb up the judicial ladder to get there.

Martin gave no reason for the long delay in asserting the ineffective assistance claims.

Citing Clark and Robbins, the court denied Martin's petition.

In turn, the Federal District Court dismissed Martin's Federal habeas petition raising the same claims.

Denial of Martin's state court petition as untimely the District Court held rested on an adequate and independent state procedural ground.

The Court of Appeals for the Ninth Circuit reversed.Contrasting the precision -- precision of fixed statutory deadlines, for example one year but California's no substantial delay formulation a Federal Appeals Court held that California's standard lacked the clarity and certainty necessary to constitute an adequate state bar.

We reversed that judgment.

In a 2009 decision, Beard -- Beard against Kindler, this Court clarified that a state procedural bar may qualify as an adequate and independent state ground for denying a federal habeas petition even if the state court had discretion to omit ruling on the procedural barrier and instead ruled on the merits.

Guided by that decision, we hold that California is not put to the choice of imposing a specific deadline for habeas petitions which would almost certainly rule out Martin's nearly five-year delay or preserving the flexibility of it's current practice but at a considerable price, opening the door to federal habeas review and thereby undermining the finality of state court judgments.

In ruling for California, we stress that Martin has not alleged that the state's time bar, either by design or in operation, discriminates against federal claims or claimants.

The opinion of the court is unanimous.