Bedford v. Bobby
645 F.3d 372
| 6th Cir. | 2011Background
- Bedford was convicted of murder and aggravated murder in 1984 and sentenced to death; direct appeals and post-conviction petitions in state courts were denied.
- Ohio set an execution date for May 17, 2011, and Bedford pursued Ford competency claims and an Atkins claim in state court.
- Bedford filed a Ford competency claim in state court on May 9, 2011, just days before the scheduled execution.
- The Ohio Supreme Court denied stays and Bedford’s state court claims were eventually rejected; Bedford sought relief in federal court.
- A federal district court granted a temporary stay to allow further Ford review, which the Sixth Circuit later vacated.
- The Sixth Circuit applied the four-factor stay test and held Bedford’s delay and lack of merit warranted vacating the stay and denying habeas relief whenever appropriate.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion by granting a stay. | Bedford waited too long to file the Ford claim. | State argues no prejudgment harm from delay; timely filing not shown. | Yes; stay vacated due to undue delay. |
| Whether Bedford has any chance of success on the Ford claim on the merits. | Bedford raised substantial questions about incompetence. | State courts reasonably rejected the claim as not meeting substantial threshold of incompetence. | No; AEDPA deference to state court adjudication stands. |
| Whether Ohio’s Ford competency procedures satisfy due process. | Ohio procedures fail to provide fair hearing. | Procedures meet Ford and Panetti requirements; inmate heard; due process satisfied. | Yes; Ohio procedures comply with due process. |
Key Cases Cited
- Ford v. Wainwright, 477 U.S. 399 (1986) (prohibition on executing the insane)
- Panetti v. Quarterman, 551 U.S. 930 (2007) (substantial threshold showing of incompetence; required fair hearing)
- Workman v. Bell, 484 F.3d 837 (6th Cir. 2007) (four-factor stay test; abuse of discretion if misapplied)
- Nelson v. Campbell, 541 U.S. 637 (2004) (equitable considerations against stay in last-minute requests)
- Gomez v. District Court, 503 U.S. 653 (1992) (last-minute nature of stay applications relevant to propriety)
- Scott v. Mitchell, 250 F.3d 1011 (6th Cir. 2001) (Ford procedures constitutional; due process considerations)
- Lonchar v. Thomas, 517 U.S. 314 (1996) (precedent on delaying federal habeas; non-merits grounds)