Ryan v. Valencia Gonzales (10-930)
argument 10-930Ryan v. Valencia Gonzales
Supreme Court of the United States
46 min
6 speakers
8 chapters
transcribed 5 days ago
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What is the Supreme Court hearing in the Ryan v. Gonzales case?
We'll now hear argument in Case 10930, Ryan v. Gonzalez.
General Horn. Mr. Chief Justice, and may it please the Court, I'd like to start picking up on a question asked by Justice Ginsburg on the Reese case. The Reese case is pre-EDPA. If there's one thing that Congress had in mind when it passed EDPA, the Anti-Terrorism and Effective Death Penalty Act, it is that the death penalty process needs to be speeded up and habeas should not result in undue delays to give effect.
You don't think that EDPA would alter the outcome of REES? You think REES would come out the other way after EDPA?
Well, I think that REES didn't really deal with our issue, which is competence to aid counsel.
Yeah, that's a different point.
Yes, I agree, Your Honor. But I thought it would be relevant to point out that it was pre-EDPA. And then on that point, this Court has said several times that habeas should not be used to grant indefinite stays. In fact, even pre-EDPA, in the Barefoot case, this Court said that habeas is not a time to retry a case and even less is it a time to grant indefinite stays. So the sentence with even less followed the sentence with not. So it was even less than not that it should grant permanent stays.
JUSTICE GINSBERG. Tell me how you define indefinite stays, meaning Are you okay with the six months to a year stay for a court to try to get someone back to competence, assuming that there is a claim in which the defendant's information is necessary?
Yes, Your Honor. We agree with the Ohio position. In the American Psychiatric Brief, I think it's page 10, note 20, they said that up to 90 percent of the cases are solved in six to nine months. And I think that if this Court set a standard of no more than a year for the successive stays, that would give some guidance to the courts.
So how do you deal with Justice Kagan's earlier question of what difference does it make if the person is still necessary or the information, potential information, is still necessary? What makes it unnecessary after a year?
Because I think the consequence of EDPA is that a balance has to be drawn between the fact that There has to be finality. In fact, this Court has said the purposes of EDPA include finality, comedy, federalism, and reduction of delays in death sentence cases. There needs to be a balance between that and the need to have a competent defendant, if we can have one, in a case where the testimony is necessary. This Court has said several times — I was going to mention also the Hines case, where this Court, I think, said very clearly that stays cannot be indefinite. So I think it would be very helpful for this Court to give a guideline to the courts and say the way to balance this is that if they get the time in which 90 percent of the cases are — But
those cases didn't establish a limit on how long states needed to take to adjudicate claims. They just said a district court should put in conditions that move things along.
Yes, that's
correct. required defendants to press their claims within a reasonable time, that required periodic updates, that required monitoring by the Court, but it didn't set an artificial end time. It just said you can't just do an open-ended stay and not give conditions to comply with. Why should this be treated differently?
Your Honor, we think it would be helpful, and we agree with Ohio on this, we think it would be helpful if the Court gave some kind of a standard so that there would be some guidance and uniformity and so that courts did not get around this court's —
How would you define that standard? What standard do you suggest?
The standard we would suggest would be that six to nine months would be the standard and certainly no more than a year, that it would be in months and not years, including not just the first day but any successive stays in all cases. Yes. In all cases where a stay was appropriate. Now, in the record-based case, no stay is appropriate.
What if the — it might be unusual, but you can't try a person who's not competent. You can't try him.
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Chapters
8 chapters
1
What is the Supreme Court hearing in the Ryan v. Gonzales case?
0:02–6:08
2
How does the Court define an “indefinite stay” under the AEDPA?
6:08–11:23
3
Why do the parties propose a six‑to‑nine‑month limit for competency stays?
11:23–16:33
4
When is a stay appropriate for a record‑based habeas petition?
16:33–21:16
5
What discretion do district courts have in granting competency stays?
21:16–27:30
6
How do ABA ethical duties affect an attorney’s duty to seek competency?
27:30–34:59
7
When should the competency‑treatment clock start running?
34:59–41:10
8
What are the final arguments on the essentiality standard and time limits?
41:10–46:27