Robinson v. Lewis

Summary

The court held that California evaluates habeas claims for timeliness on a claim-by-claim basis under an overall substantial-delay standard, rather than treating the petition as a whole or treating gap delay as a separate deadline. Gap delay is relevant to the overall analysis, but a filing within 120 days after a lower court's denial is a safe harbor and cannot be considered substantial delay based on that gap alone. The court answered the Ninth Circuit's certified question accordingly.