Belton v. Shoop, 3:24-cv-00655

Anthony Belton was convicted of aggravated murder in 2012, sentenced to death, and has unsuccessfully pursued direct appeal and post-conviction relief in Ohio courts.
In 2021, Ohio enacted a law prohibiting the death penalty for persons with certain serious mental illnesses (SMI), which can be applied retroactively if timely raised.
Belton filed a petition in Ohio state court arguing he is ineligible for the death penalty due to bipolar disorder, a qualifying SMI, and later amended the petition.
Concurrently, Belton filed a federal habeas corpus petition raising 17 grounds for relief, several challenging his sentence’s constitutionality.
Belton moved to stay federal habeas proceedings pending the outcome of his state SMI petition, arguing it may render some or all habeas claims moot.
The Warden opposed, arguing neither AEDPA nor Rhines v. Weber supports a stay for a state-law claim, and a stay would undermine federal habeas efficiency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the federal habeas should be stayed pending state SMI litigation	Stay is needed while SMI litigation proceeds and may moot federal claims	Rhines does not apply to state-law claims; stay would undermine AEDPA	Stay granted under court’s discretionary authority; limited delay justified
Application of Rhines v. Weber to state-law claims	Rhines serves as persuasive authority for issuing a stay	Rhines only applies to federal exhaustion issues; not relevant here	Rhines not strictly applicable but court has equitable discretionary authority
Impact of stay on interests of parties and judicial efficiency	Stay will promote efficiency and judicial economy	Stay may cause unnecessary delay and undermine AEDPA goals	Limited stay would serve judicial efficiency; no undue delay expected
Whether Petitioner engaged in dilatory tactics	Timely filings in both state and federal court; no undue delay	Not specifically contested	No finding of delay or abuse by Petitioner

Rhines v. Weber, 544 U.S. 269 (2005) (establishing criteria for stay and abeyance in federal habeas actions with mixed exhausted and unexhausted claims)
Landis v. North American Co., 299 U.S. 248 (1936) (recognizing court’s inherent discretionary authority to stay proceedings)
Clinton v. Jones, 520 U.S. 681 (1997) (district court’s broad discretion to manage its docket)
O'Sullivan v. Boerckel, 526 U.S. 838 (1999) (state courts must have full opportunity to resolve constitutional claims before federal review)
Rose v. Lundy, 455 U.S. 509 (1982) (total exhaustion requirement for federal habeas petitions)
Woodford v. Garceau, 538 U.S. 202 (2003) (AEDPA's purpose in reducing delays in capital cases)
Burton v. Stewart, 549 U.S. 147 (2007) (new sentence amounts to new judgment for habeas purposes)
Berman v. United States, 302 U.S. 211 (1937) (sentence is the judgment in a criminal case)
Magwood v. Patterson, 561 U.S. 320 (2010) (new judgment allows for a new habeas petition)