Facts of the Case
Ernest Valencia Gonzales was convicted for the murder of Darrel Wagner. His
conviction and death sentence became final on January 8, 1996. Gonzalez
invoked his state-court post-conviction relief opportunities before
challenging his conviction in federal court.
In November 1999, Gonzalez started a federal habeas proceeding, which
brought up 60 claims for federal habeas relief, including ones that related his
competence and ability to rationally communicate with his
court-appointed attorneys. Ultimately, the district
court denied his motion for a competency hearing and a stay of
proceedings claiming this irrelevant because his claims could not benefit from
communication with counsel.
Gonzalez appealed to the U.S. Court of Appeals for the Ninth Circuit. It
disagreed with the lower court and claimed that he was entitled to a stay
pending a competency determination. The Arizona Department of Corrections
appealed.
Tibbals v. Carter was a similar capital murder appeal from the
U.S. Court of Appeals for the Sixth Circuit. Sean Carter, the
defendant, was determined to be incompetent to assist his attorneys following his murder
conviction. The district court gave him a stay on his habeas corpus
proceedings based on a right to competence in such proceedings. After the
appellate court affirmed, the State appealed further and the Court granted
certiorari to answer the same question as in Ryan v. Gonzalez.
conviction and death sentence became final on January 8, 1996. Gonzalez
invoked his state-court post-conviction relief opportunities before
challenging his conviction in federal court.
In November 1999, Gonzalez started a federal habeas proceeding, which
brought up 60 claims for federal habeas relief, including ones that related his
competence and ability to rationally communicate with his
court-appointed attorneys. Ultimately, the district
court denied his motion for a competency hearing and a stay of
proceedings claiming this irrelevant because his claims could not benefit from
communication with counsel.
Gonzalez appealed to the U.S. Court of Appeals for the Ninth Circuit. It
disagreed with the lower court and claimed that he was entitled to a stay
pending a competency determination. The Arizona Department of Corrections
appealed.
Tibbals v. Carter was a similar capital murder appeal from the
U.S. Court of Appeals for the Sixth Circuit. Sean Carter, the
defendant, was determined to be incompetent to assist his attorneys following his murder
conviction. The district court gave him a stay on his habeas corpus
proceedings based on a right to competence in such proceedings. After the
appellate court affirmed, the State appealed further and the Court granted
certiorari to answer the same question as in Ryan v. Gonzalez.
Legal Issue
Does a death row inmate have the right to suspend federal habeas corpus
proceedings when found incompetent to assist counsel?
At issue is whether the district court's denial of Gonzalez's motion for a competency hearing and a stay of proceedings violated his 6th amendment right to have the Assistance of Counsel for his Defense, 8th amendment right to no cruel or unusual punishments inflicted, 9th amendment right to not be denied or disparaged of rights retained by his person, and his 10th amendment right to have power not delegated to the U.S. constitution respectively to his person.
proceedings when found incompetent to assist counsel?
At issue is whether the district court's denial of Gonzalez's motion for a competency hearing and a stay of proceedings violated his 6th amendment right to have the Assistance of Counsel for his Defense, 8th amendment right to no cruel or unusual punishments inflicted, 9th amendment right to not be denied or disparaged of rights retained by his person, and his 10th amendment right to have power not delegated to the U.S. constitution respectively to his person.
Arguments for both sides
Prosecution:
-claimed this irrelevant because his claims could not benefit from communication with counsel
-implicates federalism concerns over the finality of state court decisions in capital cases and the proper balance between the rights of victims and the rights of inmates.
-the consequence of AEDPA is that a balance has to be drawn between the fact that there has to be finality.
Defense:
-cases didn't establish a limit on how long states needed to adjudicate claims
-district courts are supposed to require defendants to press their claims within a reasonable time that required updates but it didn't set an artificial end time.
-presumption of valid conviction can be overturned by the petitioner or prisoner which Gonzalez can't do.
-claimed this irrelevant because his claims could not benefit from communication with counsel
-implicates federalism concerns over the finality of state court decisions in capital cases and the proper balance between the rights of victims and the rights of inmates.
-the consequence of AEDPA is that a balance has to be drawn between the fact that there has to be finality.
Defense:
-cases didn't establish a limit on how long states needed to adjudicate claims
-district courts are supposed to require defendants to press their claims within a reasonable time that required updates but it didn't set an artificial end time.
-presumption of valid conviction can be overturned by the petitioner or prisoner which Gonzalez can't do.
Applicable Precedents
Barefoot v. Estelle, 463 U.S. 880 (1983)
-The Supreme Court previously ruled on a Texas death penalty case regarding
the use of a psychiatric examination to determine the defendant's competency to stand trial
to predict future dangerousness. In that case the Court held that the Fifth Amendment's privilege against
self-incrimination applied to pretrial psychiatric examinations by a prosecution
psychiatrist who later testified the defendant's future dangerousness
without warning the defendant that such evidence could be used against him.
The Supreme Court ruled that:
"There is no merit to petitioner's argument that psychiatrists, individually and
as a group, are incompetent to predict with an acceptable degree of reliability
that a particular criminal will commit other crimes in the future, and so
represent a danger to the community. ...Nor, despite the view of the American
Psychiatric Association supporting petitioner's view, is there any convincing
evidence that such testimony is almost entirely unreliable, and that the
factfinder and the adversary system will not be competent to uncover, recognize,
and take due account of its shortcomings".
This case regards the competency of the defendant and the testimony of psychiatrists and medical opinion to determine whether or not a stay of execution was admissible, similar to the stay of proceeding requested by Gonzalez.
Rees v. Peyton, 384 U.S. 312 (1966)
- The Defendant filed a habeas corpus petition in the District Court alleging that a subsequent
related state murder conviction on which he was sentenced to death violated his
constitutional rights. Defense petitioned for certiorari to review the Court of Appeals' affirmance of the District
Court's rejection of his claims of ordering counsel to withdraw the
petition and forgo further legal proceedings.The Petitioner's counsel advised the Court that, since evidence
cast doubt on his client's mental competency, he could not conscientiously do so
without a psychiatric evaluation of petitioner. A psychiatrist he retained
examined Rees and pronounced him incompetent. State-selected psychiatrists
were unable to examine Rees for lack of his cooperation, but doubted him insane.
The Supreme Court ruled that;
"...Whether or not Rees shall be allowed in these circumstances to withdraw his
certiorari petition is a question which it is ultimately the responsibility of
this Court to determine, in the resolution of which Rees' mental competence is
of prime importance. We have therefore determined that, in aid of the proper
exercise of this Court's certiorari jurisdiction, the Federal District Court in which this proceeding commenced
should upon due notice to the State and all other interested parties make a
judicial [384 U.S. 312, 314] determination as to Rees' mental competence and render a report on the matter to us. While other
courses have been suggested, cf. Anderson v. Kentucky, 376 U.S. 940 , we think that all things
considered the initial step should be the one just indicated. Until that step
has been taken, we do not consider ourselves in a position to determine what
disposition should be made of Rees' petition for certiorari...".
This case regards the competence of the defendant to an extent that he cannot cooperate with his counsel and through psychiatric examination by psychiatrists selected by the state they deemed him incapable of standing trial. The Supreme court allowed district court to rule on the basis that they take in mind the medical examinations and regard the federal statute in 18 U.S.C section 4241.
-The Supreme Court previously ruled on a Texas death penalty case regarding
the use of a psychiatric examination to determine the defendant's competency to stand trial
to predict future dangerousness. In that case the Court held that the Fifth Amendment's privilege against
self-incrimination applied to pretrial psychiatric examinations by a prosecution
psychiatrist who later testified the defendant's future dangerousness
without warning the defendant that such evidence could be used against him.
The Supreme Court ruled that:
"There is no merit to petitioner's argument that psychiatrists, individually and
as a group, are incompetent to predict with an acceptable degree of reliability
that a particular criminal will commit other crimes in the future, and so
represent a danger to the community. ...Nor, despite the view of the American
Psychiatric Association supporting petitioner's view, is there any convincing
evidence that such testimony is almost entirely unreliable, and that the
factfinder and the adversary system will not be competent to uncover, recognize,
and take due account of its shortcomings".
This case regards the competency of the defendant and the testimony of psychiatrists and medical opinion to determine whether or not a stay of execution was admissible, similar to the stay of proceeding requested by Gonzalez.
Rees v. Peyton, 384 U.S. 312 (1966)
- The Defendant filed a habeas corpus petition in the District Court alleging that a subsequent
related state murder conviction on which he was sentenced to death violated his
constitutional rights. Defense petitioned for certiorari to review the Court of Appeals' affirmance of the District
Court's rejection of his claims of ordering counsel to withdraw the
petition and forgo further legal proceedings.The Petitioner's counsel advised the Court that, since evidence
cast doubt on his client's mental competency, he could not conscientiously do so
without a psychiatric evaluation of petitioner. A psychiatrist he retained
examined Rees and pronounced him incompetent. State-selected psychiatrists
were unable to examine Rees for lack of his cooperation, but doubted him insane.
The Supreme Court ruled that;
"...Whether or not Rees shall be allowed in these circumstances to withdraw his
certiorari petition is a question which it is ultimately the responsibility of
this Court to determine, in the resolution of which Rees' mental competence is
of prime importance. We have therefore determined that, in aid of the proper
exercise of this Court's certiorari jurisdiction, the Federal District Court in which this proceeding commenced
should upon due notice to the State and all other interested parties make a
judicial [384 U.S. 312, 314] determination as to Rees' mental competence and render a report on the matter to us. While other
courses have been suggested, cf. Anderson v. Kentucky, 376 U.S. 940 , we think that all things
considered the initial step should be the one just indicated. Until that step
has been taken, we do not consider ourselves in a position to determine what
disposition should be made of Rees' petition for certiorari...".
This case regards the competence of the defendant to an extent that he cannot cooperate with his counsel and through psychiatric examination by psychiatrists selected by the state they deemed him incapable of standing trial. The Supreme court allowed district court to rule on the basis that they take in mind the medical examinations and regard the federal statute in 18 U.S.C section 4241.
Supreme Court Justices
John G. Roberts, Jr., Chief Justice of the United States, Antonin Scalia, Associate Justice, Anthony M. Kennedy, Associate Justice, Clarence Thomas, Associate Justice, Ruth Bader Ginsburg, Associate Justice, Stephen G. Breyer, Associate Justice, Samuel Anthony Alito, Jr., Associate Justice, Sonia Sotomayor, Associate Justice, Elena Kagan, Associate Justice,
John G. Roberts, Jr.:
Chief Justice John G. Roberts, Jr. insists he is "not an ideologue," and
that he believes in "modest" jurisprudence, indicating he is disinclined toward
judicial activism, a label usually applied to liberal courts.
Roberts is conservative and a Federalist who has publicly disagreed with
many of the decisions of the Warren Court (Chief Justice Earl Warren,
1953-1969).
Antonin Scalia, Associate Justice:
Justice Antonin Scalia is a conservative. He is one of two justices on the
court (the other being Clarence Thomas) who believe in the philosophy of
constitutional originalism, that the Constitution should be interpreted solely
in terms of the framers original intent.
For example, if a case come up challenging a punishment as "cruel and
unusual" originalists like Scalia would look at what the founding fathers
felt were cruel and unusual and if he felt the punishment would have been approved by
the founders then he would find the punishment being challenged as constitutional.
The justices with the living constitution philosophy, on the other hand, would look to see
whether the particular punishment fit into what society generally considers to be cruel and
unusual. Since the founding fathers were much more tolerant of very severe forms
of punishment than people generally are today, Scalia would be more likely to
rule that a particular punishment is constitutional than the justices who
believe in the living constitution.
In response to these justices, Chief Roberts Jr. is more likely to be sympathetic and/or lenient to the claim of incompetency rather than Scalia who would be more inclined to harsher punishments and ignorance of medical diseases/incompetence i.e. "you're a killer and you will pay rightfully regardless of circumstance". I expect Chief Roberts Jr. to be in favor of the respondent and reason with the medical inclination of incompetence and 18 U.S.C. section 4241, accordingly. However, I presume that Justice Scalia would be more likely to rule for the Petitioner and deny any stays of execution due to incompetence and directly deem the district court correct and constitutional in its decision.
John G. Roberts, Jr.:
Chief Justice John G. Roberts, Jr. insists he is "not an ideologue," and
that he believes in "modest" jurisprudence, indicating he is disinclined toward
judicial activism, a label usually applied to liberal courts.
Roberts is conservative and a Federalist who has publicly disagreed with
many of the decisions of the Warren Court (Chief Justice Earl Warren,
1953-1969).
Antonin Scalia, Associate Justice:
Justice Antonin Scalia is a conservative. He is one of two justices on the
court (the other being Clarence Thomas) who believe in the philosophy of
constitutional originalism, that the Constitution should be interpreted solely
in terms of the framers original intent.
For example, if a case come up challenging a punishment as "cruel and
unusual" originalists like Scalia would look at what the founding fathers
felt were cruel and unusual and if he felt the punishment would have been approved by
the founders then he would find the punishment being challenged as constitutional.
The justices with the living constitution philosophy, on the other hand, would look to see
whether the particular punishment fit into what society generally considers to be cruel and
unusual. Since the founding fathers were much more tolerant of very severe forms
of punishment than people generally are today, Scalia would be more likely to
rule that a particular punishment is constitutional than the justices who
believe in the living constitution.
In response to these justices, Chief Roberts Jr. is more likely to be sympathetic and/or lenient to the claim of incompetency rather than Scalia who would be more inclined to harsher punishments and ignorance of medical diseases/incompetence i.e. "you're a killer and you will pay rightfully regardless of circumstance". I expect Chief Roberts Jr. to be in favor of the respondent and reason with the medical inclination of incompetence and 18 U.S.C. section 4241, accordingly. However, I presume that Justice Scalia would be more likely to rule for the Petitioner and deny any stays of execution due to incompetence and directly deem the district court correct and constitutional in its decision.
My Personal Decision
I believe that according to the 6th, 8th, and 9th amendments that the respondent should receive his stay of proceedings and continue thus until deemed appropriate of permanent incompetence. In a case regarding ruling on the mentally ill, disabled, and or incompetent the courts should lean on the sense that it acts as a significant right to be given certain treatment for conditions like so; a right retained by the people. Therefore, Gonzalez's request for a stay of proceedings, in my opinion, should not be infringed on and denied.
Annotated Bibliography
"Biographies of Current Justices of the Supreme Court." Home - Supreme
Court of the United States. N.p., n.d. Web. 29 Jan. 2013. <http://www.supremecourt.gov/about/biographies.aspx>.
This website was used to search for the biographies of the Supreme Court
Justices etc.
"18 USC § 4241 - Determination of mental
competency to stand trial to undergo postrelease proceedings? | Title 18 -
Crimes and Criminal Procedure | U.S. Code | LII / Legal Information Institute."
LII | LII / Legal Information Institute. N.p., n.d. Web. 29 Jan.
2013. <http://www.law.cornell.edu/uscode/text/18/4241>.
This site was informative is the description of the Federal Statute 18 U.S.C
section 4241 regarding competency.
"FindLaw | Cases and Codes." FindLaw: Cases and Codes. N.p., n.d. Web.
29 Jan. 2013. <http://caselaw.lp.findlaw.com/cgi-bin/getcase.pl?court=US&vol=384&invol=312>.
This website I used to find the rulings on the case Rees v. Peyton since it was
mentioned and cited profusely.
"Ryan v. Gonzales | The Oyez Project at IIT Chicago-Kent College of Law."
The Oyez Project at IIT Chicago-Kent College of Law | A Multimedia Archive of
the Supreme Court of the United States. N.p., n.d. Web. 29 Jan. 2013. <http://www.oyez.org/cases/2010-2019/2012/2012_10_930>.
I used this website to research the facts of the case and help understand the
issue at hand.
. "Barefoot v. Estelle - 463 U.S. 880 (1983) :: Justia US Supreme Court
Center." US Law, Case Law, Codes, Statutes & Regulations :: Justia US
Supreme Court Center. N.p., n.d. Web. 29 Jan. 2013. <http://supreme.justia.com/cases/federal/us/463/880/case.html>.
I used this site to search information about the preceding case of Barefoot v.
Estelle.
Court of the United States. N.p., n.d. Web. 29 Jan. 2013. <http://www.supremecourt.gov/about/biographies.aspx>.
This website was used to search for the biographies of the Supreme Court
Justices etc.
"18 USC § 4241 - Determination of mental
competency to stand trial to undergo postrelease proceedings? | Title 18 -
Crimes and Criminal Procedure | U.S. Code | LII / Legal Information Institute."
LII | LII / Legal Information Institute. N.p., n.d. Web. 29 Jan.
2013. <http://www.law.cornell.edu/uscode/text/18/4241>.
This site was informative is the description of the Federal Statute 18 U.S.C
section 4241 regarding competency.
"FindLaw | Cases and Codes." FindLaw: Cases and Codes. N.p., n.d. Web.
29 Jan. 2013. <http://caselaw.lp.findlaw.com/cgi-bin/getcase.pl?court=US&vol=384&invol=312>.
This website I used to find the rulings on the case Rees v. Peyton since it was
mentioned and cited profusely.
"Ryan v. Gonzales | The Oyez Project at IIT Chicago-Kent College of Law."
The Oyez Project at IIT Chicago-Kent College of Law | A Multimedia Archive of
the Supreme Court of the United States. N.p., n.d. Web. 29 Jan. 2013. <http://www.oyez.org/cases/2010-2019/2012/2012_10_930>.
I used this website to research the facts of the case and help understand the
issue at hand.
. "Barefoot v. Estelle - 463 U.S. 880 (1983) :: Justia US Supreme Court
Center." US Law, Case Law, Codes, Statutes & Regulations :: Justia US
Supreme Court Center. N.p., n.d. Web. 29 Jan. 2013. <http://supreme.justia.com/cases/federal/us/463/880/case.html>.
I used this site to search information about the preceding case of Barefoot v.
Estelle.