Supreme Court Allows Some Limited Stays for Competency in Habeas Appeals
The U.S. Supreme Court has ruled that federal courts have the equitable power to issue limited stays when inmates are incompetent to assist in their habeas proceedings.
But the unanimous opinion (PDF) by Justice Clarence Thomas rejected arguments that prisoners have a statutory right to competency stays in habeas appeals that is derived from federal statutes. And Thomas said that, in most cases, an inmate’s mental incompetence during a habeas proceeding will not eviscerate his statutory right to counsel.
“Given the backward-looking, record-based nature of most federal habeas proceedings, counsel can generally provide effective representation to a habeas petitioner regardless of the petitioner’s competence,” Thomas said. “Attorneys are quite capable of reviewing the state-court record, identifying legal errors, and marshaling relevant arguments, even without their clients’ assistance.”
Thomas ruled on Tuesday in the consolidated cases of two death row inmates, Ernest Valencia Gonzales and Sean Carter. Gonzales was convicted in the stabbing death of an Arizona man during a burglary of his home, while Carter was convicted in the rape and stabbing death of his adoptive grandmother in Ohio. Thomas’ decision could benefit Carter when the courts consider his case on remand.
Thomas said there is no right to competency deriving a federal statute providing for the appointment of counsel for indigent capital defendants pursuing habeas appeals. Nor is there a right in a federal law providing for competency proceedings before trial, or after the beginning of probation or supervised release, he said.
Thomas did acknowledge, however, that federal judges had the equitable power to stay proceedings based on incompetence of a habeas petitioner. That argument could apply to one of Carter’s claims in which evidence outside the record could be helpful, Thomas said, but the record is unclear. In any event, he said, some time limits are necessary.
“If a district court concludes that [Carter’s] claim could substantially benefit from the petitioner’s assistance, the district court should take into account the likelihood that the petitioner will regain competence in the foreseeable future,” Thomas wrote. “Where there is no reasonable hope of competence, a stay is inappropriate and merely frustrates the state’s attempts to defend its presumptively valid judgment.”
Gonzales won’t benefit from Thomas’ ruling because the lower courts found that all of his habeas claims can be resolved as a matter of law, regardless of his competence. “Counsel can read the record,” Thomas wrote.
The consolidated cases are Ryan v. Gonzales and Tibbals v. Carter. The ABA has filed an amicus brief supporting appropriate stays for competency and use of a flexible standard in the determination.
Prior coverage:
ABAJournal.com: “High Court Appears Skeptical of Indefinite Stays for Competency in Capital Appeals”
ABAJournal.com: “ABA Amicus Brief Says Mental Incompetency May Require Stays in Capital Habeas Proceedings”
ABAJournal.com: “Supreme Court to Decide on Competency Delays in Death-Row Habeas Cases”
