Walker v. Martin

562 U.S. 307 (2011)

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Nature of the Case

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Facts

In December 1986, Martin (P) participated in a robbery and murder in California. P fled the State, but eight years later he was extradited to California to stand trial. Convicted in state court of murder and robbery, P was sentenced to life in prison without the possibility of parole. In 1997, the California Court of Appeal affirmed his conviction and sentence, and the California Supreme Court denied review. In 1998 the California Supreme Court denied his petition. He then filed a habeas petition in District Court. P's federal petition included ineffective-assistance-of-counsel claims he had not aired in state court. The District Court stayed the federal proceedings pending P's return to state court to exhaust his remedies In March 2002, P filed his second habeas petition in the California Supreme Court. P alleged ineffective assistance of counsel in a habeas petition filed in the California Supreme Court nearly five years after his conviction became final. He stated no reason for the long delay. The court denied P's petition. The District Court then dismissed P's federal habeas petition raising the same ineffective-assistance claims. The District Court held that the denial rested on an adequate and independent state ground. The U. S. Court of Appeals reversed. It held that California's standard lacked the clarity and certainty necessary to constitute an adequate state bar. It was remanded to District Court. The District Court again rejected P's petition, stating that “the California timeliness bar as set forth in . . . Clark/Robbins is clearly defined, well established and consistently applied.” The Ninth Circuit reversed; “California's time bar “has yet to be firmly defined” and was not shown by the State to be “consistently applied.” The Supreme Court granted certiorari.