The Supreme Court ruling in Ryan v. Gonzales is available in Adobe .pdf format.
"Justices Rule on Staying Death Row Challenges," is the title of Adam Liptak's report in today's New York Times.
The Supreme Court on Tuesday unanimously ruled that federal courts should not automatically suspend postconviction challenges from death row inmates who are mentally incompetent to help their lawyers. The decision left open the possibility that such suspensions may sometimes be warranted, but it said that they should not be indefinite.
“Where there is no reasonable hope of competence,” Justice Clarence Thomas wrote for the court, “a stay is inappropriate.”
The Supreme Court has ruled that it is unconstitutional to put mentally incompetent defendants on trial because they cannot understand the proceedings against them or assist their lawyers. The court has also barred “carrying out a sentence of death upon a prisoner who is insane.”
Tuesday’s decision in a pair of cases — Ryan v. Gonzales, No. 10-930, and Tibbals v. Carter, No. 11-218 — concerned challenges brought after trial and before execution. One involved Ernest Valencia Gonzales, who was convicted of stabbing an Arizona couple in front of their 7-year-old son, killing the father. The other concerned Sean Carter, an Ohio man convicted of raping his adoptive grandmother and stabbing her to death.
By the time the federal courts considered the two men’s challenges to their state court convictions, there was substantial evidence that they were mentally incompetent. Relying on different federal statutes, the appeals courts in the two cases said that the challenges must await their return to mental competence.
When the cases were argued in October, Justice Samuel A. Alito Jr. said he was concerned that the rulings were a ploy “that will permit stays in virtually every capital case” because “a lot of district judges and a lot of court of appeals judges don’t like the death penalty and will go to some length to prevent the imposition of that sentence.”
At SCOTUSblog, Lyle Denniston posts the analysis, "Opinion recap: Rees clarified, after forty-six years."
For more than forty-six years, the Supreme Court’s brief rulings in the Virginia death row case of Melvin Davis Rees, Jr., have remained in the Supreme Court’s records, but few have paid attention to them since and their meaning was never clarified. The Justices finally did so on Tuesday, ruling that the actions it took in Rees v. Peyton in 1966 and 1967 did not give state prisoners a right to delay their federal court challenges until they are mentally competent enough to proceed. No federal law, the Court decided unanimously, gives an incompetent state prisoner any right to keep a habeas case on hold until he can regain mental understanding of what is going on. The habeas case can go ahead with just the lawyers involved, the ruling said.
Although the Court did not say so explicitly, the new decision in Ryan v. Gonzales (10-930) also appeared to mean that state prisoners have no freestanding right to be competent so that they can take part when their case gets into a federal habeas court — an issue separate from whether they had a right to a delay while they remain incompetent. (Decided along with the Ryan case, from Arizona, was a companion case from Ohio, Tibbals v. Carter, 11-218.) Justice Clarence Thomas wrote the nine-to-zero decision.
The Rees case of nearly five decades ago has been one of the Court’s most abiding mysteries. After ordering a test of his mental capacity, and then being told that Rees was incompetent, the Court in 1967 simply placed his case in a state of perpetual inactivity — until Rees died in prison, some twenty-eight years later, in 1995. Then, the Court responded by dismissing his case in two words.
"Top court says prisoner incompetence no bar to appeal," is by Jonathan Stempel for ReutersLegal.
Two death row inmates were not entitled to a delay of their federal appeals on the grounds that they were incompetent to assist their lawyers, the U.S. Supreme Court said on Tuesday.
In a unanimous ruling against inmates Ernest Valencia Gonzales and Sean Carter, the court also said federal judges cannot indefinitely delay appeals of state criminal convictions in the hope that the defendants might eventually become competent enough to help out.
Justice Clarence Thomas said defense lawyers are "quite capable" of reviewing cases without their clients' help and can identify arguments or state court errors that can be raised on appeal.
He said a district judge who believes an incompetent defendant could substantially aid in his defense should examine the likelihood that the defendant will regain competence.
In contrast, "where there is no reasonable hope of competence, a stay merely frustrates the state's attempts to defend its presumptively valid judgment," Thomas wrote.
Local coverage of the cases includes:
"Ruling: U.S. judges can suspend some death-row appeals," by Michael Kiefer in the Arizona Republic.
"Court rules on Trumbull man’s appeal," is by Christopher Bobby in Ohio's Warren Tribune Chronicle.
Earlier coverage of Ryan v. Gonzales begins at the link.