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Supreme court upholds California timeliness rule for habeas petitions

By Sarah Miley

[JURIST] The US Supreme Court [official website; JURIST news archive] on Wednesday ruled [opinion, PDF] unanimously in Walker v. Martin [Cornell LII backgrounder; JURIST report] that a state law barring a prisoner from collaterally attacking his conviction is adequate to support a procedural bar to filing a habeas corpus petition. The decision upholds a California state law preventing prisoners from collaterally attacking their judgment when the prisoner "substantially delayed" filing his habeas petition. Writing the opinion for the court, Justice Ruth Bader Ginsburg noted that the court has the responsibility to ensure that state procedural claims do not discriminate against claims of federal rights, but determined that California's timeliness rule does not operate to the particular disadvantage of such rights of the petitioner. Ginsburg stated that recent precedent [JURIST report] gave clear guidance on the issue:

In a recent decision, Beard v. Kindler, ... this Court clarified that a state procedural bar may count as an adequate and independent ground for denying a federal habeas petition even if the state court had discretion to reach the merits despite the default. 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 current practice, but only at the cost of undermining the finality of state court judgments. In so ruling, we stress that Martin has not alleged that California's time bar, either by design or in operation, discriminates against federal claims or claimants.

The judgment reversed Ninth Circuit decision [opinion, PDF], which held that the state's law was not well-established or "consistently applied" and therefore did not constitute a procedural bar to collaterally attacking the conviction.

The petitioner, Charles Martin, was sentenced to life without parole for murder and filed a habeas petition alleging ineffective assistance of counsel in the California Supreme Court, nearly fives years after his conviction became final. He had no explanation for the delay in the filing. The court dismissed Martin's claim as untimely under the California law. Having exhausted his state remedies, Martin filed a federal habeas petition in the US District Court for the Eastern District of California [official website] raising the same issues. The district court dismissed the petition as untimely stating that the rejection "rested on an adequate and independent state ground, i.e., Martin's failure to seek relief in state court without substantial delay."

Full post as published by JURIST - The Paper Chase on February 23, 2011 (boomark / email).