The US Supreme Court held [opinion, PDF] Wednesday in Ayestas v Davis [SCOTUSblog materials] that the US Court of Appeals for the Fifth Circuit [official website] applied the wrong standard when they denied Carlos Ayestas funding for investigative services in his habeas petition.
Ayestas was convicted of murder and sentenced to death in a Texas court. He argues that he was “wrongfully denied funding for investigative services [which he] needed to prove his entitlement to federal habeas relief.” Ayestas sought investigative funding in order for the court to hear his mental health and alcohol and drug history, but was denied by the district court because there was a failure to raise this concern at the state level.
Upon review, the appeals court upheld the district court’s holding because Ayestas did not present a “substantial need” for funding and failed to raise a constitutional claim. The Supreme Court explained that this application of 18 USC §3599(f) [text] was incorrect:
The Fifth Circuit did not apply the correct legal standard in affirming the denial of petitioner’s funding request. Section 3599 authorizes funding for the “reasonably necessary” services of experts, investigators, and the like. But the Fifth Circuit’s requirement that applicants show a “substantial need” for the services is arguably a more demanding standard. Section 3599 appears to use the term “necessary” to mean something less than essential. Because it makes little sense to refer to something as being “reasonably essential,” the Court concludes that the statutory phrase calls for the district court to determine, in its discretion, whether a reasonable attorney would regard the services as sufficiently important, guided by considerations detailed in the opinion. The term “substantial” in the Fifth Circuit’s test, however, suggests a heavier burden.
The Supreme Court has remanded the case on the grounds that the court must use a “reasonable necessary” standard in determining whether Ayestas could receive funding without considering the absence of a constitutional violation.