In re Robbins, 18 Cal. 4th 770 (1998), and In re Gallego, 18 Cal. 4th 825 (1998) "explained many aspects of the timeliness rules applicable to petitions for writs of habeas corpus" after the California Supreme Court's decision in In re Clark, 5 Cal. 4th 750 (1993). In re Sanders, 21 Cal. 4th 697, 701 (1999). Here, the Ninth Circuit found that even though Robbins and Gallego had only been decided three months prior, Hart was nevertheless on notice of California's timeliness rule under Clark when he filed his habeas petition in the California Supreme Court. Thus, the Ninth Circuit found that Clark, standing alone, was adequate to bar his claim that the prosecution suppressed material impeachment evidence regarding an informant who testified at his capital trial.

Did the Ninth Circuit misapply the standard for adequate state grounds, in conflict with this Court's precedent in Coleman v. Thompson, 501 U.S. 722 (1991), and Lee v. Kemna, 534 U.S. 362, 375 (2002), when it found that California's timeliness bar under Clark was "firmly established and regularly followed" and applied that bar to Hart's habeas petition?

Did the Ninth Circuit misapply the standard for adequate state grounds when it found California's timeliness bar was 'firmly established and regularly followed' and applied that bar to Hart's habeas petition?