Ryan v. Valencia Gonzales, 133 S. Ct. 696

Gonzales, a Arizona death-row inmate, filed federal habeas after exhausting state remedies, while his counsel sought a stay arguing incompetence would prevent rational communication and aid.
District Court denied a stay, finding Gonzales’ claims were record-based or legally resolvable without his input; Ninth Circuit granted mandamus staying proceedings pending a competency determination.
Carter, an Ohio death-row inmate, sought competency determination and stayed proceedings; District Court found him incompetent to assist counsel and dismissed petition without prejudice with tolling.
Sixth Circuit held that §4241 provides a statutory right to competence, permitting an indefinite stay for claims requiring the petitioner’s assistance; it remanded to stay those claims.
Supreme Court granted certiorari to decide whether §3599 or §4241 creates a right to competence and a stay, and whether district courts have authority to stay habeas proceedings on incompetence grounds.
Court reverses the Ninth and Sixth Circuits, holding §3599 and §4241 do not provide a right to stay for incompetence; discusses district court discretion and limits on stays.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does §3599 provide a statutory right to competence and stay?	Gonzales argued §3599 implies a stay when incompetent to assist counsel.	Ryan argued §3599 does not create a stay right and is limited to appointment of counsel and related services.	No statutory right to stay; §3599 does not authorize stays for incompetence.
Does §4241 provide a statutory right to competence in habeas proceedings?	Carter argued §4241 grants competence rights in habeas actions and supports stays.	Carter argued §4241 applies to trial proceedings, not habeas; no competence right in habeas.	No statutory right to competence in habeas under §4241.
Are district courts empowered to stay capital habeas proceedings on incompetence grounds as an equitable matter?	Gonzales and Carter urged broad discretion to stay pending competence.	Courts should apply outer limits of stay discretion and avoid indefinite interruptions.	Stay authority is limited; indefinite stays are inappropriate; focus on outer limits of discretion.
How should courts treat record-based claims and potential new input from a incompetent petitioner?	Competence could aid with record-based or exhausted-merits claims.	Record-based review limits extrarecord evidence; AEDPA aims for finality and discourages delay.	For Gonzales, no stay where claims are record-based; for Carter, stays disfavored if they delay AEDPA finality.

Rohan v. Woodford, 334 F.3d 803 (9th Cir. 2003) (cogent discussion on competence and right to counsel in habeas)
Nash v. Ryan, 581 F.3d 1048 (9th Cir. 2009) (habeas competence on appeal)
Rees v. Peyton, 384 U.S. 312 (1966) (death-row habeas; competence context post-petition withdrawal)
Rees v. Superintendent of Va. State Penitentiary, 516 U.S. 802 (1995) (Rees III; competence and reformulation of proceedings)
McFarland v. Scott, 512 U.S. 849 (1994) (right to counsel context and stay-ability in capital cases)
Carter v. Bradshaw, 644 F.3d 329 (6th Cir. 2011) (6th Cir. held §4241 provides competence right in habeas context)
Rhines v. Weber, 544 U.S. 269 (2005) (AEDPA stay limits to avoid indefinite delays; finality goal)
Pinholster, 563 U.S. _ (2011) (AEDPA review limited to record before state court (note: official reporter citation not included here))
Harrington v. Richter, 562 U.S. _ (2011) (use of highly deferential standards in §2254 review (no pin citation provided))
Cooper v. Oklahoma, 517 U.S. 348 (1996) (competence and due process considerations separate from right to counsel)