A Collaboration with the University of Pittsburgh

Supreme Court rules habeas cases can proceed with lawyer, incompetent client

The US Supreme Court [official website] ruled unanimously [opinion, PDF] on Tuesday in the combined cases Ryan v. Gonzales [JURIST report] and Tibbals v. Carter that there is no right to stay a federal habeas corpus proceeding until an inmate becomes competent. The court held, rather, that the proceeding can continue with only the attorney. Justice Clarence Thomas delivered the opinion of the court.

Both Gonzales and Carter argued at length in their briefs and at oral argument that district courts have the equitable power to stay proceedings when they determine that habeas petitioners are mentally incompetent. Neither petitioner disputes that "[d]istrict courts ... ordinarily have authority to issue stays, where such a stay would be a proper exercise of discretion." Similarly, both petitioners agree that "AEDPA does not deprive district courts of [this] authority." Petitioners and respondents disagree, however, about the types of situations in which a stay would be appropriate and about the permissible duration of a competency-based stay. We do not presume that district courts need unsolicited advice from us on how to manage their dockets. Rather, the decision to grant a stay, like the decision to grant an evidentiary hearing, is "generally left to the sound discretion of district courts." For purposes of resolving these cases, it is unnecessary to determine the precise contours of the district court’s discretion to issue stays. We address only its outer limits.
The decision clarified the 1966 decision Rees v. Peyton [opinion].

Rees involved a convicted murderer who attempted to withdraw his petition for certiorari from the Supreme Court, which his attorney, in good conscience, could not do. A psychiatrist then declared Rees mentally incompetent. The court retained jurisdiction by a stay [order text] until the federal district court could make a report on Melvin Rees' competency. Rees died in prison in 1995. The court then dismissed [order text] certiorari in a brief order.

About Paper Chase

Paper Chase is JURIST's real-time legal news service, powered by a team of 30 law student reporters and editors led by law professor Bernard Hibbitts at the University of Pittsburgh School of Law. As an educational service, Paper Chase is dedicated to presenting important legal news and materials rapidly, objectively and intelligibly in an accessible format.

© Copyright JURIST Legal News and Research Services, Inc., 2013.