In a rare unanimous ruling, the Supreme Court narrowed another avenue of appeals for death row inmates, ruling that federal judges cannot indefinitely delay appeals of state criminal convictions in the hope that an incompetent defendant might eventually become competent enough to help his or her lawyer out with the appeals process.
The ruling came from a pair of cases. Both Ernest Valencia Gonzales and Sean Carter were convicted of murder and received capital sentences. Both brought legal challenges in federal court after their state court trials. By the time the federal courts actually considered the two men’s challenges to their state court convictions, there was significant evidence that they were both mentally incompetent. In both cases the appeals courts said the challenges must wait until the men could return to mental competence but relied on different federal statutes to support that conclusion.
Writing for the bench, Justice Clarence Thomas dismissed outright the idea that a defendant must be competent in order to assist his or her attorney with the appeals process. Noting that postconviction challenges typically are based on the court record and nothing else, an inmate would have very little to add to the appellate process, said Thomas. “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.”
Furthermore, 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.
Instead of relying on a cloudy area of case law to support their claim that they were entitled to stays pending competency, the inmates 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.”
While this may sound like bad news for anti-death penalty advocates, the decision is not as bad as it may seem. Right now a prisoner’s competency to assist counsel is an issue in approximately a dozen capital cases pending nationwide Dale Baich, an attorney at the federal public defender’s office that represented one of the defendants told Reuters. And the Supreme Court’s decision leaves open room for federal courts to put some appeals on hold which means that rather than a blanket ruling holding that competency is not required to assist in an appeal, the Supreme Court crafted a narrower standard that tries to reflect some of the practical realities of litigating criminal cases, even capital ones.
We’ve yet to adequately deal with how to assess the guilt or culpability of a mentally ill individual which means we ultimately have no guarantee those we are trying and executing are mentally competent, and indeed the evidence usually suggests closer to the opposite is true. Unfortunately, until states and Congress eradicate capital punishment entirely, something that doesn’t seem likely in the immediate future, this kind of decision is going to have to count as a win.
Photo from decade_null via flickr.