Daniel Lopez v. William Stephens, Director
783 F.3d 524
5th Cir.2015Background
- Lopez, a death-row inmate in Texas, sought to waive further federal habeas review and to dismiss counsel; district court appointed counsel and held a competency hearing under Rees v. Peyton.
- The district court conducted a face-to-face inquiry with Lopez, reviewed extensive mental-health records, and heard testimony from court-appointed expert Dr. Timothy J. Proctor, who interviewed and tested Lopez and concluded he was competent to waive habeas review.
- The court found Lopez understood the proceedings, the role of the court, and the consequences of waiving review; Lopez consistently expressed a desire for the State to carry out his sentence and religious readiness for death.
- Defense counsel appealed the competency finding and argued Lopez was incompetent because he mistakenly believed further review would be unavailing (relying on impaired vision/pepper spray facts) and sought funding for additional neuropsychological and investigatory services.
- The district court denied additional funding; the Fifth Circuit reviewed whether the competency inquiry met Rees/Mata standards and whether Dr. Proctor’s evaluation sufficed as the meaningful opportunity to present competency evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Competency to waive federal habeas | Lopez lacks capacity because he is mistaken about prospects for relief (e.g., vision/intentionality facts) | District court’s face-to-face inquiry, record review, and Dr. Proctor’s evaluation show Lopez appreciated his position and made a rational choice | Competency finding affirmed — no bona fide doubt under Rees/Mata; legal merits of habeas claims do not determine competency |
| Funding for additional experts/investigation | Counsel sought funds for a second neuropsychologist and investigatory services, arguing Dr. Proctor missed aspects of Lopez’s mental history | Court-appointed expert reviewed ~10,000 pages, conducted interviews/tests, and testified; one thorough evaluation satisfied Mata’s requirement for meaningful opportunity to present evidence | Denial of additional funding affirmed; one comprehensive court-appointed expert evaluation was constitutionally sufficient |
Key Cases Cited
- Rees v. Peyton, 384 U.S. 312 (standard for competency to abandon appeals)
- Mata v. Johnson, 210 F.3d 324 (5th Cir. 2000) (procedures and measures for competency inquiry in capital habeas context)
- Autry v. McKaskle, 727 F.2d 358 (5th Cir. 1984) (competency finding distinct from merits/legal avenues of attack)
- Henderson v. Campbell, 353 F.3d 880 (11th Cir. 2003) (affirming separation of competency inquiry from merits of habeas claims)