Supreme Court upholds California's loose rules for inmate appeals

McClatchy NewspapersFebruary 23, 2011 

WASHINGTON — The Supreme Court on Wednesday upheld California's relatively flexible approach to handling inmates' appeals.

In a case that arose out of a 1986 Sacramento murder, the court unanimously accepted California's unusual standard for deciding when inmates have waited too long to challenge their convictions. Unlike most states, California doesn't set a specific deadline.

"Discretion enables a court to home in on case-specific considerations and to avoid the harsh results that sometimes attend consistent application of an unyielding rule," Justice Ruth Bader Ginsburg wrote for the court.

By contrast, Idaho and 12 other states set strict one-year habeas corpus deadlines once convictions are final. Florida and three other states set two-year deadlines. Texas and 15 other states set fixed deadlines of various lengths. Sixteen other states have no deadlines.

The 13-page decision rejecting the appeal of convicted killer Charles W. Martin united the court's liberal and conservative wings, perhaps for different reasons.

All agreed that California is reasonable in requiring only that inmates file habeas corpus petitions "as promptly as the circumstances allow." Liberals, such as Ginsburg, could emphasize the advantages of discretion. Conservatives could avoid unsettling the way California's Supreme Court handles hundreds of inmate petitions annually.

The decision in Walker v. Martin also gave the conservative-dominated U.S. Supreme Court another opportunity to overturn a decision by the San Francisco-based 9th U.S. Circuit Court of Appeals.

Martin filed his habeas corpus petition nearly five years after his conviction for the murder of Charles Stapleton became final.

Stapleton had been stabbed eight times in the neck, back and throat. Children playing along the Sacramento River discovered his body, stuffed into a plywood box, on Dec. 7, 1986. Eight years later, Martin was captured in Florida.

Convicted of first-degree murder and robbery, he was sentenced to life without possibility of parole.

In March 2002, Martin filed his habeas corpus petition with the California Supreme Court. He claimed that his original trial attorney was ineffective. Martin, for instance, claimed that the attorney had allowed the jury to hear certain questionable statements made by a drug addict who testified for the prosecution and had failed to investigate another suspect.

The state court said Martin had waited too long, and law-and-order advocates agreed.

"Although California's flexibly defined timeliness standard may be uncertain in some cases, there is no doubt five years after (final conviction) is untimely," Kent Scheidegger, the legal director for the Sacramento-based Criminal Justice Legal Foundation, argued in a brief.

The California Supreme Court rejected more than 1,350 inmate petitions in the first six months of last year. Often, the reason cited was that the petition came too late. On the same day in 2002 that the state court turned away Martin's petition as tardy, it rejected 21 other inmate petitions on similar grounds.

Martin's appellate attorneys argued that the state's overly flexible guideline for judging timeliness left inmates in the dark.

"The exhortation to file reasonably promptly fails to provide meaningful guidance," Martin's Sacramento-based appellate lawyer, Michael B. Bigelow, argued in a brief.

Ginsburg, writing for the U.S. Supreme Court, countered that states should be able to adopt "supple prescriptions" that guided when inmates must file their petitions, so that inmates wouldn't "lose the opportunity" to potentially secure review of their convictions.

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