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Name: Walker v. Martin
Case #: 09-996
Court: US Supreme Court
District USSup
Opinion Date: 02/23/2011
Subsequent History: 131 S.Ct. 1120; 179 L.Ed.2d 62

California’s timeliness requirement for the filing of a habeas petition qualifies as an independent state ground adequate to bar habeas corpus relief in the federal court. In California, there is not a determinate time limit for habeas relief. Instead, a prisoner must seek relief without “substantial delay,” as measured from the time petitioner or counsel knew, or reasonably should have known, of the information in support of the claim and the legal basis of the claim. A summary denial by the California Supreme Court which cites In re Clark (1993) 5 Cal.4th 750, and In re Robbins (1998) 18 Cal.4th 770, means that the petition was rejected as untimely. Here, the U.S. Supreme Court held that the California rule, although discretionary, qualifies to bar habeas relief in the federal court.