In a recent decision, Beard v. Kindler, ... this Court clarified that a state procedural bar may count as an adequate and independent ground for denying a federal habeas petition even if the state court had discretion to reach the merits despite the default. Guided by that decision, we hold that California is not put to the choice of imposing a specific deadline for habeas petitions (which would almost certainly rule out Martin's nearly five-year delay) or preserving the flexibility of current practice, but only at the cost of undermining the finality of state court judgments. In so ruling, we stress that Martin has not alleged that California's time bar, either by design or in operation, discriminates against federal claims or claimants.

The petitioner, Charles Martin, was sentenced to life without parole for murder and filed a habeas petition alleging ineffective assistance of counsel in the California Supreme Court, nearly fives years after his conviction became final. He had no explanation for the delay in the filing. The court dismissed Martin's claim as untimely under the California law. Having exhausted his state remedies, Martin filed a federal habeas petition in the US District Court for the Eastern District of California [official website] raising the same issues. The district court dismissed the petition as untimely stating that the rejection "rested on an adequate and independent state ground, i.e., Martin's failure to seek relief in state court without substantial delay."