[JURIST] The US Supreme Court [official website; JURIST news archive] on Tuesday ruled [opinion, PDF] in Beard v. Kindler [Cornell LII backgrounder; JURIST report] that a state procedural rule is not automatically "inadequate" to bar federal habeas review under the adequate state ground doctrine. The case arose when the Pennsylvania courts applied the state's fugitive forfeiture rule and concluded that defendant Joseph Kindler waived his right to seek appellate review, dismissing his appeal without reaching the merits of his claims. The Court vacated the decision of the US Court of Appeals for the Third Circuit, which had affirmed [opinion, PDF] the district court's grant of federal habeas relief. Chief Justice John Roberts wrote for the Court:

We hold that a discretionary state procedural rule can serve as an adequate ground to bar federal habeas review. Nothing inherent in such a rule renders it inadequate for purposes of the adequate state ground doctrine. To the contrary, a discretionary rule can be "firmly established" and "regularly followed" — even if the appropriate exercise of discretion may permit consideration of a federal claim in some cases but not others.