Oral argument in Walker v. Martin set for Monday, November 29
The United States Supreme Court will hear oral argument Monday in California’s appeal of a federal Ninth Circuit ruling, which ignored the state’s deadline for filing state habeas corpus petitions and permitted yet another round of review in the case of convicted murderer Charles W. Martin.
At issue in the case of Walker v. Martin is whether federal courts may overlook rules governing state habeas corpus proceedings simply because, in the federal court’s opinion, the rules have not been rigidly applied.
The Sacramento-based Criminal Justice Legal Foundation has joined the case to argue that federal courts should not be allowed to ignore state procedural rules, such as deadlines for filing a state habeas petition, so long as a defendant had adequate notice of the rule and a reasonable opportunity to comply with it.
“We need fair rules that limit these repeated attacks on the same conviction and still provide enough flexibility to deal with unusual situations,” said the Foundation’s Legal Director Kent Scheidegger. “The Ninth Circuit has run roughshod over the state’s rules to give clearly guilty murderers additional bites at the apple, and we are asking the Supreme Court to put a stop to this,” he added.
This case involves the murder of Charles Stapleton. In 1986, children playing along the banks of the Sacramento River discovered a box containing a corpse, later identified as Stapleton. He had been stabbed eight times in the neck, back, and throat. The children also found Martin’s wallet nearby. A few days later, Martin’s girlfriend made statements further implicating him in the crime. Martin was convicted of first-degree murder and sentenced to life without the possibility of parole.
Martin appealed his conviction, challenging the prosecution’s use of the girlfriend’s statement at trial. The California Court of Appeal rejected his claim and affirmed his conviction. The California Supreme Court declined to review his case in April 1997.
Ten months later, Martin sought further review of his conviction by filing a state habeas petition in the California Superior Court. This time, Martin attacked the performance of his trial attorney and claimed errors related to the jury pool and jury instructions. The petition was denied. Martin filed similar petitions in the California Court of Appeal and the California Supreme Court, both of which were denied.
In 2002, after an unsuccessful attempt at federal habeas relief and nearly five years after his first appeal was final, Martin filed another state habeas petition making several new allegations. The California Supreme Court denied the petition, ruling the claims were defaulted because Martin had waited too long to make them.
Martin again turned to federal court. The Federal District Court determined that, because Martin had gone past the time limit to present his claims in state court, the federal court could not address them. On appeal, the Ninth Circuit ordered the District Court to overlook California’s deadline and address the challenges Martin raised to his conviction. The Ninth Circuit determined that California’s deadline rule, which requires that a state habeas petition be filed “as promptly as the circumstances allow” absent a good excuse for the delay, was inadequate to block the federal court from hearing Martin’s claims. In support of its ruling, the Ninth Circuit noted that California had not “consistently applied” the rule.
For the U. S. Supreme Court review of that ruling, CJLF has introduced a scholarly amicus curiae (friend of the court) brief to argue that federal courts should not be allowed to ignore state rules. California and other states have the authority to set deadlines and other rules for their own habeas corpus proceedings, and the federal courts should not be allowed to arbitrarily invalidate them unless they place an unreasonable burden on the defendant or violate the Constitution or U. S. Supreme Court precedent.
“A state’s decision to build some flexibility into its rules is not a basis for striking them down,” said CJLF Legal Director Kent Scheidegger. “States provide mechanisms for challenging a conviction, and the murderer in this case had ample opportunity to present his claims. He chose instead to wait several years before filing his latest petition. The Ninth Circuit ruling punishes the state for allowing some reasonable discretion when circumstances prevent a defendant from filing his claims promptly.”