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A California state court convicted Charles Martin of robbery and murder and sentenced him to life in prison without the possibility of parole. Subsequently, Mr. Martin filed a round of habeas petitions in state court – all of which were denied. He then raised several new claims in petitions for federal habeas relief in a California federal district court. The court denied to examine the claims because they were not yet exhausted in state court. After Mr. Martin exhausted these last claims in state court, he returned to federal court for federal habeas corpus relief. The district court again denied the petition relying on California's statute of limitations for filing state habeas corpus petitions.

On appeal, the U.S. Court of Appeals for the Ninth Circuit reversed the district court, holding that California's statute of limitations could not operate as an independent and adequate state ground to bar federal habeas corpus review. The court reasoned that California's statute of limitations was not sufficiently defined, nor consistently applied such that it could bar Mr. Martin's petition.

In a federal habeas corpus proceeding, is a state law barring a prisoner from attacking his conviction an insufficient procedural bar because the federal court thinks the rule is (1) vague and (2) the state failed to prove that the bar is consistently applied?

No. The Supreme Court reversed the lower court decision in a unanimous opinion by Justice Ruth Bader Ginsburg. The Court held that the California rule requiring state habeas petitions to be filed "as promptly as the circumstances allow" constitutes an independent state ground that is adequate to bar habeas relief in federal court.