What is the test for timely filing in a federal habeas case?

First, Madera County found the petition untimely. California's timeliness rule is clearly established and not interwoven with federal law. See Walker v. Martin, 562 U.S. 307, 317 (2011). California applies a "reasonableness standard" to judge whether a habeas petition is timely; a habeas petition must be filed without "substantial delay." Id. at 397. A "reasonable time" to file is generally less than 60 days. See Evans v. Chavis, 546 U.S. 189, 201 (2006). Here,

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petitioner's state-level habeas petition was filed in July 2015, nearly four years after his December 2011 sentencing.