Stanley v. Cullen
633 F.3d 852
| 9th Cir. | 2011Background
- Stanley was convicted in California state court of arson, burglary, and first-degree murder with special circumstances making him death-eligible.
- During penalty phase, a §1368 competency hearing was ordered; a separate jury found him competent, after which the penalty phase resumed and he was sentenced to death.
- California courts denied habeas relief; Stanley filed federal habeas petition raising guilt and penalty-phase claims, including competency issues.
- The district court held a biased juror rendered the competency verdict invalid and remanded to determine feasibility of a penalty-phase competency retrial, staying other claims.
- Judge Hollows’ findings and district court rulings formed the basis for the §54(b) judgment certifying relief on some claims and abeyance of others.
- Stanley challenges multiple procedural and substantive aspects of the federal proceedings, including due process, ineffective assistance, and remand/stay procedures.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the state court violated due process by not sua sponte ordering a guilt-phase competency hearing | Stanley | Cullen | No due process violation; no bona fide doubt warranted sua sponte hearing |
| Whether trial counsel were ineffective for not seeking guilt-phase competency proceedings | Stanley | Cullen | No Strickland error; record shows counsel relied on medications and routine assessments |
| Whether counsel were ineffective for failing to present a diminished capacity defense during guilt phase | Stanley | Cullen | No abuse of discretion; insufficient evidence to justify an evidentiary hearing |
| Whether remand to state court to determine feasibility of a penalty-phase competency retrial was proper | Stanley | Cullen | Proper; feasibility determination can be made by state court |
| Whether the Rule 54(b) judgment and stay of remaining claims were appropriate | Stanley | Cullen | Appropriate discretion to certify final judgments and stay remaining claims |
Key Cases Cited
- Drope v. Missouri, 420 U.S. 162 (1975) (due process right not to be tried while incompetent)
- Pate v. Robinson, 383 U.S. 375 (1966) (requirement of competency inquiry when doubt arises)
- Dusky v. United States, 362 U.S. 402 (1960) (definition of competency to stand trial)
- Maxwell v. Roe, 606 F.3d 561 (9th Cir. 2010) (evidence and testimonial considerations for competency issues)
- United States v. Clark, 617 F.2d 180 (9th Cir. 1980) (district court credibility in competency determinations)
- Hernandez v. Ylst, 930 F.2d 714 (9th Cir. 1991) (counsel's position on defendant's comprehension relevant to competency)
- Odle v. Woodford, 238 F.3d 1084 (9th Cir. 2001) (court's consideration of post-conviction evidence on competency)
- Miles v. Stainer, 108 F.3d 1109 (9th Cir. 1997) (remand procedure and state court competency considerations)
- Blazak v. Ricketts, 971 F.2d 1408 (9th Cir. 1992) (role of interrelated claims in Rule 54(b) analysis)
- Stone v. Powell, 428 U.S. 465 (1976) (limits on grant of habeas relief for pretrial suppression claims)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-prong standard for ineffective assistance of counsel)
- Pirtle v. Morgan, 313 F.3d 1160 (9th Cir. 2002) (independent review when state court gives no reasoning)
- Davis v. Woodford, 384 F.3d 628 (9th Cir. 2004) (abuse of discretion standard for evidentiary hearings)
- Harrington v. Richter, 562 U.S. __ (2011) (standard for AEDPA review when state court decision lacks reasoning)
- Williams v. Taylor, 529 U.S. 362 (2000) (clarifies clearly established law for AEDPA deference)