Not complying with a state statute of limitations is a sufficient and independent state ground which impedes further review in the United States Supreme Court. In the same manner, if the state court judgment is sustainable on the ground of laches, the Supreme Court review of a state court decision is impeded.
A statute of limitations issue can bar Supreme Court review if it appears that it offers and independent and adequate ground for decision. In Paschall v. Christie-Stewart, Inc., 414 U.S. 100 (U.S. 1973), it was held by the Supreme Court that if, after the oral argument and review of the record, it appears that there might have been an independent ground for the judgment of the state trial court, based on the applicable statute of limitations, any decision by the United States Supreme Court on the constitutionality of a challenged statute would be advisory and beyond its jurisdiction. On appeal, the Supreme Court vacated the judgment and remanded the case to the state supreme court to consider whether the statute of limitations defense has been properly preserved and if it independently impedes review, regardless of the merits of the constitutional issue presented.