Ryan v. Gonzalez

Whether an indigent death row inmate is entitled to stay the federal habeas proceedings he initiated if he is not competent to assist counsel.

Respondent was convicted of murder and sentenced to death. Respondent exhausted his state-court post-conviction relief opportunities and initiated a federal habeas corpus proceeding. By this time respondent’s mental health had deteriorated to the point that he had lost the ability to rationally communicate with his counsel and was unable to assist them and respondent's counsel filed a motion for a stay pending a competency determination under Rohan ex rel. Gates v. Woodford. 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 reversed and granted the stay of the lower court proceedings.

Petitioner argues that the Constitution does not provide a right to counsel on federal habeas review so there is no basis for the Ninth Circuit’s holding. Additionally, petitioner argues that the Supreme Court has never found a federal right to be competent to assist habeas counsel, and that since 18 U.S.C. § 3599(a)(2) does not address a defendant’s competence, there is no reasoned basis for concluding that Congress intended that death penalty habeas proceedings should be stayed or that enforcement of a presumptively valid state court judgment should be suspended indefinitely based on a death row inmate’s alleged inability to assist counsel.