Ryan v. Gonzales

Facts of the Case

Respondent Ernest Valencia Gonzales, a death row inmate in Arizona, sought federal habeas relief. His counsel moved to stay the proceedings, contending that Gonzales’ mental incompetence prevented him from rationally communicating with or assisting counsel, and that Gonzales was thus entitled to a stay because, under the Ninth Circuit’s

Question

Does a death row inmate have the right to suspend federal habeas corpus proceedings when found incompetent to assist counsel?

CONCLUSION

No. In a unanimous opinion, Justice Clarence Thomas reversed the judgment of the Ninth Circuit and vacated the judgment of the Sixth Circuit. The Court reasoned that neither a statutory nor a constitutional right to competence exists during federal habeas corpus proceedings. Though the district court has broad discretion to grant a stay on habeas proceedings, this discretion is not without its limitations. In both cases, a stay was unwarranted because communication between the defendant and his attorney was unnecessary. The record provided adequate information for an attorney to handle habeas proceedings on his own, regardless of a client’s incompetence. Even if the district court were to decide that the defendant’s competence was necessary, it should only grant a stay if the defendant is likely to regain competence in the foreseeable future. Otherwise, allowing a stay on their proceedings would unreasonably burden the judicial system.

Case Information

  • Citation: 568 US 57 (2013)
  • Granted: Mar 19, 2012
  • Argued: Oct 9, 2012
  • Decided Jan 8, 2013