Walker v. Martin

Summary

The Supreme Court held that California's discretionary timeliness rule for postconviction habeas petitions—directing petitioners to file known claims "as promptly as the circumstances allow" and barring "substantial delay"—is firmly established and regularly followed, and therefore qualifies as an adequate and independent state ground barring federal habeas review. Discretionary, indeterminately phrased procedural rules do not become inadequate merely because outcomes vary case to case, and Martin alleged neither discrimination against federal claims nor an unfair, surprising application of the rule to him. The Court accordingly reversed the Ninth Circuit, which had deemed the bar too vague under its Townsend precedent, thereby restoring the procedural default of Martin's belated ineffective-assistance claims. No separate opinions were filed.