Ryan v. Gonzales & Tibbals v. Carter v. Solis

State prisoners have no right to a stay of their record-based habeas proceedings when they are adjudged incompetent.

Respondent Gonzales was convicted of murder and sentenced to death in Arizona. After Gonzales ceased communications with counsel, his attorneys filed a motion for a stay pending a competency determination. The district court concluded that respondent’s claims were record-based and involved purely legal issues that would not be impacted by respondent’s inability to communicate with counsel and denied his motion. The Court of Appeals for the Ninth Circuit cited its decision in Rohan ex rel. Gates v. Woodford, 334 F. 3d 803 (2003), in which the Ninth Circuit held that what is now codified as 18 U.S.C. §3599 guaranteed state capital prisoners a right to counsel in federal habeas proceedings, and that the statute could not “be faithfully enforced unless courts ensure that a petitioner is competent,” reversed the district court, and granted the stay of the lower court proceedings.

Likewise Respondent Carter, a death row inmate in Ohio, stopped communicating with counsel and his attorneys filed a habeas petition along with a motion for a competency hearing. The district court granted the motion and found that Carter was not sufficiently competent to assist his counsel. On appeal, the Court of Appeals for the Sixth Circuit held that 18 U.S.C. §4241 granted a right to competence and stayed Carter’s proceeding.

The Supreme Court reversed, holding that in record-based proceedings like those at issue here, it is unnecessary for the petitioner to be competent in order for counsel to be effective. The Court held that 18 U.S.C. § 4241 is limited to proceedings prior to sentencing and after probation, and because a habeas proceeding falls between those times, there is no right to suspend habeas proceedings when the petitioner is adjudged incompetent.