ATA v. Scutt
2011 U.S. App. LEXIS 23678
| 6th Cir. | 2011Background
- Ata was convicted of intentional murder and possession of a firearm during a felony in Michigan.
- Pretrial and trial records showed Ata had a long history of serious mental illness, including paranoid schizophrenia.
- Post-conviction proceedings in state court denied relief and were followed by denials from state appellate courts.
- Ata filed a federal habeas petition in 2008, asserting ineffective assistance and involuntary confession, and sought equitable tolling.
- The district court granted summary judgment dismissing the petition, rejecting tolling due to lack of evidence linking mental illness to late filing.
- The Sixth Circuit vacated and remanded to hold an evidentiary hearing on equitable tolling based on mental incompetence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| May mental incompetence toll AEDPA's deadline? | Ata asserts mental illness is an extraordinary circumstance entitling tolling. | State contends no causal link and no evidentiary basis for tolling. | Mental incompetence may toll if causally connected to filing delay. |
| Does Ata's petition allege a sufficient causal link between mental incapacity and untimely filing? | Allegations show hospitalization and medicating and lack of understanding of the deadline. | Allegations are insufficient and conclusory without causal connection. | Allegations are sufficiently specific to require an evidentiary hearing on causation. |
| Is an evidentiary hearing required to resolve equitable tolling based on mental incompetence? | Hearing necessary to verify factual allegations and tying them to tolling. | Hearing not automatic; state record may refute claims. | An evidentiary hearing is required if specific allegations would entitle tolling. |
Key Cases Cited
- Schriro v. Landrigan, 550 U.S. 465 (Supreme Court, 2007) (standard for deciding habeas evidentiary hearings)
- Holland v. Florida, 560 U.S. 631 (Supreme Court, 2010) (equitable tolling requires diligence and extraordinary circumstance)
- Pace v. DiGuglielmo, 544 U.S. 408 (Supreme Court, 2005) (diligence + extraordinary circumstance for tolling)
- Hunter v. Ferrell, 587 F.3d 1304 (11th Cir., 2009) (mental incapacity can warrant tolling with proper causation)
- Bolarinwa v. Williams, 593 F.3d 226 (2d Cir., 2010) (evidentiary hearing warranted for mental-illness tolling allegations)
- Laws v. Lamarque, 351 F.3d 919 (9th Cir., 2003) (petitioner’s mental illness can trigger tolling where supported)
- Riva v. Ficco, 615 F.3d 35 (1st Cir., 2010) (supports tolling based on psychological impairment with causation)