competency

Issues

In 1999, Ahmad Edwards stole a pair of shoes from an Indiana department store and then shot at the store security guard who chased after him, wounding the guard and a passer-by. The State of Indiana charged Edwards with theft, criminal recklessness, battery, and attempted murder. In 2004, an Indiana trial court declared Edwards competent to stand trial but later denied Edwards' request to serve as his own lawyer. The judge said that Edwards, a diagnosed schizophrenic, was not competent to represent himself. Edwards then went to trial with counsel, a jury found him guilty, and he was sentenced to thirty years in prison. Edwards appealed, arguing that the court deprived him of his Sixth Amendment right to represent himself at trial. The Indiana Court of Appeals agreed with Edwards and called for a new trial. The appeals court held that once the trial court had found Edwards competent to stand trial, under United States Supreme Court precedent, the court could not impose a higher competency standard to determine whether he could act as his own lawyer. The Indiana Supreme Court affirmed the appeals court's decision. The Supreme Court will consider whether states may impose greater competency standards on defendants who wish to represent themselves than on ordinary defendants.

Questions as Framed for the Court by the Parties

Issues

An Arizona jury convicted Ernest Valencia Gonzales of first-degree murder and sentenced him to death in 1991. After exhausting his state court options, Gonzales initiated federal habeas proceedings in 1999. Over the next few years, Gonzales began to display signs of delusion and paranoia, refusing a number of attempted visits from his attorney. The district court denied his attorney’s motion to stay the habeas proceedings pending a competency determination. The Ninth Circuit eventually granted mandamus relief, holding that the capital inmate’s right to counsel in federal habeas proceedings under 18 U.S.C. § 3599(a)(2) implicitly includes a right to be competent to assist one’s counsel. Charles L. Ryan, Director of the Arizona Department of Corrections, appeals the Ninth Circuit’s decision arguing that the circuit court misread 18 U.S.C. § 3599(a)(2) to include a “right to competency” in assisting counsel. Ryan asserts that such a right would allow for indefinite stays of habeas proceedings based on incompetency that contravene Congress’ intent in the Antiterrorism and Effective Death Penalty Act. Gonzales contends that district courts have discretion to issue stays, and that such stays are appropriate where incompetency would deprive the capital inmate of “meaningful” right to counsel. This decision 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.

Questions as Framed for the Court by the Parties

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