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Tibbals v. Carter, sub nom. Ryan v. Gonzales

Public Citizen represented Sean Carter, who was convicted of capital murder despite conflicting expert opinions regarding his competence to stand trial. He has since been diagnosed with schizophrenia, and his condition causes him to experience hallucinations, has led him to mistake a witness against him for his own lawyer, and renders him unable to remember the verdict at his trial or communicate effectively with his lawyers about his trial. On post-conviction review, the district court found him incompetent to understand the nature of the proceedings or assist his attorneys in seeking relief from his conviction and sentence. The court of appeals stayed the proceedings until he regains competence. Public Citizen, working with the Office of the Ohio Public Defender, represented Carter before the U.S. Supreme Court. We argued that courts have discretion to stay post-conviction proceedings to prevent the forfeiture of potentially valid claims due to an individual’s mental illness. In a 9-0 decision, the Court held that lower courts do have discretion to stay cases in these circumstances, but that three of the four claims stayed in Carter’s case should not have been stayed because his assistance was not necessary to pursue the claims. As to the fourth claim, the Court held that a stay would be appropriate if the claim was unexhausted and not procedurally defaulted, and Carter’s assistance was needed to pursue the claim.