RESPONDENT: Ernest Valencia Gonzales
LOCATION: Darrel Wagner's Town House
DOCKET NO.: 10-930
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Ninth Circuit
CITATION: 568 US (2013)
GRANTED: Mar 19, 2012
ARGUED: Oct 09, 2012
DECIDED: Jan 08, 2013
Ann O'Connell - Assistant to the Solicitor General, Department of Justice, for the United States, as amicus curiae, supporting the petitioners in Nos. 11-218 and 10-930
Alexandra T. Schimmer - Solicitor General of Ohio, for the petitioner in No. 11-218
Leticia Marquez - for the respondent
Scott Michelman - for the respondent in No. 11-218
Thomas C. Horne - Attorney General of Arizona, for the petitioner
Facts of the case
Ernest Valencia Gonzales was convicted for the murder of Darrel Wagner. His conviction and death sentence became final on January 8, 1996. Gonzalez exhausted his state-court post-conviction relief opportunities before challenging his conviction in federal court.
In November 1999, Gonzales initiated a federal habeas proceeding, which raised 60 claims for federal habeas relief, including claims relating to Gonzales' competence and ability to rationally communicate with his court-appointed attorneys. The federal court stayed Gonzales' execution pending resolution of those proceedings. Ultimately, the district court denied Gonzales' motion for a competency hearing and a stay of proceedings. Even though it determined that Gonzales was incompetent, the court considered this irrelevant because Gonzales' claims could not benefit from rational communication with counsel.
Gonzales appealed to the U.S. Court of Appeals for the Ninth Circuit. It disagreed with the lower court and held that Gonzales was entitled to a stay pending a competency determination. The Arizona Department of Corrections appealed.
The related case, Tibbals v. Carter, was a similar capital murder appeal from the U.S. Court of Appeals for the Sixth Circuit. Sean Carter, the defendant, was adjudged incompetent to assist his attorneys following his murder conviction. The district court granted Carter a stay on his habeas corpus proceedings based on a right to competence in such proceedings. After the appellate court affirmed, the State appealed further and the Court granted certiorari to answer the same question as in Ryan v. Gonzales.
Does a death row inmate have the right to suspend federal habeas corpus proceedings when found incompetent to assist counsel?
Media for Ryan v. GonzalesAudio Transcription for Oral Argument - October 09, 2012 in Ryan v. Gonzales
Audio Transcription for Opinion Announcement - January 08, 2013 in Ryan v. Gonzales
John G. Roberts, Jr.:
Justice Thomas has our opinion this morning in Case No. 10-930, Ryan vs. Gonzales and No. 11-218 Tibbals versus Carter.
Ryans -- Ryan versus Gonzales comes to us on a writ of certiorari to the United States Court of Appeals for the Ninth Circuit.
Tibbals versus Carter comes to us in a writ of certiorari to the United States Court of Appeals for the Sixth Circuit.
In the first case, Ryan versus Gonzales, Valencia Gonzales, a death row inmate in Arizona, sought Federal Habeas Relief.
His counsel moved to stay the proceedings on the grounds that Gonzales was mentally incompetent and that his incompetence prevented him from rationally communicating with or assisting counsel.
The District Court denied a stay finding that the claims before it were record-based on resolvable as a matter of law and thus, would not benefit from Gonzales' input.
Gonzales then sought a Writ of Mandamus in the Ninth Circuit Court of Appeals.
The Ninth Circuit applied its recent decisions in Nash versus Ryan and Rohan versus Woodford, and concluded that Section 3599 of Title 18 of the United States Code gave Gonzales the right to stay pending competency proceedings.
In the second case, Tibbals versus Carter, Sean Carter, death row inmate in Ohio, likewise initiated Federal Habeas proceedings but eventually moved for competency determination and a stay of proceedings.
The District Court granted the motion because it found Carter incompetent to assist counsel.
Relying on the Ninth Circuit's decision in Rohan, the Court determined that Carter's assistance was needed in order to develop four of his claims.
It thus dismissed as habeas petition without prejudice and perspectively told statute of limitations.
On appeal to Sixth Circuit relying in part on our decision in Rees versus Peyton found a statutory right to competence in Section 4241 of Title 18 of the U.S. Code which provides a mechanism for competency determinations in certain situations.
It thus ordered that Carter's petition be stayed indefinitely with respect to any claims requiring his assistance.
In an opinion filed with the clerk today, we reverse in both cases.
The Ninth Circuit located a right to competency in Section 3599, which grants federal habeas petitioners on death row, the right to federally funded counsel, but nothing in the text of the statute provides habeas petitioners with the right to stay of proceedings when they are found to be incompetent.
Furthermore, we have never held that a right to competence is a component of the right to counsel.
We, therefore, will not assume that Congress embedded a right to competency-based stays within Section 3599's right to counsel.
The Ninth Circuit first identified the right to competency-based stays in Rohan, concluding there that a petitioner's mental incompetence could have eviscerate the statutory right to counsel in federal habeas proceedings.
But given the backward looking record-based nature of Section 2254 proceedings, counsel can generally provide effective assistance to a habeas petitioner regardless of the petitioner's competence.
Moreover, our decision in Rees versus Paton, which involved an incompetent death row inmate's attempt to withdraw his petition for certiorari offers no support for Gonzales' position because Rees did not so much as suggest the possibility of a statutory right to competence, much less hold that such a right exist.
The Sixth Circuit's approach is similarly incorrect.
Section 4241 does not provide a statutory right to stay of federal habeas proceedings based on a petitioner's incompetence.
The Sixth Circuit based its holding largely on a misreading of our decision in Rees, which as noted, did not recognize such a right.
Moreover, Section 4241 does not apply to federal habeas proceedings.
By its own terms, it applies only to federal trial proceedings before sentencing and “at anytime after the commencement of probation or supervised release.”
Federal habeas proceedings fall into neither of these categories.
As part of their inherent power to manage their dockets, District Courts ordinarily have the authority to issue stays where a stay would be a proper exercise of discretion.
We hold that a stay is generally unwarranted however when a petitioner raises only record-based claims subject to review under Section 2254(d), because counsel may present such claims regardless of the petitioner's competence.
We also hold that indefinite stays are inappropriate because they frustrate the state's attempts to defend their presumptively valid judgments.