WASHINGTON — The Supreme Court on Tuesday unanimously ruled that federal courts should not automatically suspend post-conviction 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.”
In Tuesday’s decision, Justice Thomas wrote that post-conviction challenges are typically based on the court record, meaning that the inmate would have nothing to add even if he were able to work with his lawyers. “Counsel can generally provide effective representation to a habeas petitioner regardless of the petitioner’s competence,” Justice Thomas wrote, adding that “attorneys are quite capable of reviewing the state-court record, identifying legal errors and marshaling relevant arguments, even without their clients’ assistance.”
The appeals courts had relied on a curious order from the Supreme Court in 1967 in Rees v. Peyton, in which the court “held without action” a request for review from a mentally incompetent death row inmate. The court finally dismissed the inmate’s petition in 1995 after his death in prison.
Justice Thomas said that procedure set no precedent and that a 1996 federal law in any event altered the legal landscape.
Lawyers for the two inmates did not try very hard to persuade the justices that the appeals courts — the United States Court of Appeals for the Ninth Circuit, in San Francisco, in Mr. Gonzales’s case and the Sixth Circuit, in Cincinnati, in Mr. Carter’s — were correct in interpreting federal statutes to require automatic stays. “Gonzales barely defends the Ninth Circuit’s interpretation,” Justice Thomas wrote. He added that “we would address Carter’s arguments in defense of the Sixth Circuit’s decision, but there are none.”
The inmates instead argued that federal trial judges should have discretion to enter stays, and the Supreme Court agreed.
“We do not presume that district courts need unsolicited advice from us on how to manage their dockets,” Justice Thomas wrote. “For purposes of resolving these cases, it is unnecessary to determine the precise contours of the district court’s discretion to issue stays.”