Walker v. Martin

Charles W. Martin (defendant) was convicted of a murder and robbery by a California state court. In 1997 the California Court of Appeal affirmed Martin’s conviction, and the California Supreme Court denied review. Five years after his conviction, Martin filed a petition for a writ of habeas corpus raising a federal ineffective-assistance-of-counsel claim and seeking relief from his conviction. California state law instructed state prisoners seeking habeas relief to file a habeas petition as quickly as possible after their convictions. If a prisoner filed a petition after a substantial delay and without an adequate justification for the delay, the California Supreme Court could deny the petition at its discretion. A series of decisions made by the California Supreme Court explained its timeliness requirements for habeas petitions, and the court regularly denied petitions for being untimely under its precedent. After the California Supreme Court denied his habeas petition, Martin filed a habeas petition in federal district court. The federal district court dismissed the petition, holding that California’s timeliness requirement for habeas petitions was an independent and adequate state ground for barring federal habeas relief. The court of appeals reversed Martin’s conviction, holding that California’s timeliness rule was too discretionary and lacked sufficient clarity to be an adequate state ground to bar habeas relief. California (plaintiff) appealed, and the United States Supreme Court granted certiorari.