Justice THOMAS delivered the opinion of the Court.
These two cases present the question whether the incompetence of a state prisoner requires suspension of the prisoner's federal habeas corpus proceedings. We hold that neither 18 U.S.C. § 3599 nor 18 U.S.C. § 4241 provides such a right and that the Courts of Appeals for the Ninth and Sixth Circuits both erred in holding that district courts must stay federal habeas proceedings when petitioners are adjudged incompetent.
Ernest Valencia Gonzales was convicted by an Arizona jury of felony murder, armed robbery, aggravated assault, first-degree burglary, and theft. The convictions arose from Gonzales' repeated stabbing of Darrel and Deborah Wagner in front of their 7-year-old son during a burglary of the Wagners' home. Darrel Wagner died from the stabbing, while Deborah Wagner survived but spent five days in intensive care. The trial court sentenced Gonzales to death on the murder charge and to various prison terms for the other crimes.
After exhausting state remedies, Gonzales filed a petition for a writ of habeas corpus in Federal District Court on November 15, 1999. While the petition was pending, Gonzales' appointed counsel moved to stay the proceedings, contending that Gonzales was no longer capable of rationally communicating with or assisting counsel. He argued that mental incompetence entitled Gonzales to a stay under Ninth Circuit precedent. See Rohan v. Woodford, 334 F.3d 803 (2003). In Rohan, the Ninth Circuit held that the federal statute guaranteeing state capital prisoners a right to counsel in federal habeas
Applying Rohan, the District Court denied a stay after concluding that the claims properly before it were record based or resolvable as a matter of law and thus would not benefit from Gonzales' input. The court found it unnecessary to determine whether Gonzales was incompetent, though it did find that he possessed "at least a limited capacity for rational communication." Gonzales v. Schriro, 617 F.Supp.2d 849, 863 (D.Ariz.2008).
Gonzales thereafter filed an emergency petition for a writ of mandamus in the Ninth Circuit. While Gonzales' petition was pending, the Ninth Circuit decided Nash v. Ryan, 581 F.3d 1048 (2009), which held that habeas petitioners have a right to competence on appeal, even though appeals are entirely record based. Id., at 1050 ("While an appeal is record-based, that does not mean that a habeas petitioner in a capital case is relegated to a nonexistent role. Meaningful assistance of appellate counsel may require rational communication between counsel and a habeas petitioner"). Applying Nash and Rohan, the court granted the writ of mandamus, concluding that even though Gonzales'"exhausted claims are record-based or legal in nature, he is entitled to a stay pending a competency determination" under 18 U.S.C. § 3599. In re Gonzales, 623 F.3d 1242, 1244 (C.A.9 2010).
We granted certiorari to determine whether § 3599 provides a statutory right to competence in federal habeas proceedings. 565 U.S. ___, ___, 132 S.Ct. 1738, 182 L.Ed.2d 528 (2012).
Sean Carter was convicted by an Ohio jury of aggravated murder, aggravated robbery, and rape, and sentenced to death for anally raping his adoptive grandmother, Veader Prince, and stabbing her to death. After exhausting his state-court appeals, Carter initiated federal habeas proceedings on March 19, 2002, in the Northern District of Ohio. Carter eventually filed a third amended petition, along with a motion requesting a competency determination and a stay of the proceedings. The District Court granted the motion.
Following several psychiatric evaluations and a competency determination, the District Court found Carter incompetent to assist counsel. Applying the Ninth Circuit's test in Rohan, it determined that Carter's assistance was required to develop four of his exhausted claims. As a result, the court dismissed his habeas petition without prejudice and prospectively tolled the statute of limitations. Carter v. Bradshaw, 583 F.Supp.2d 872, 884 (N.D.Ohio 2008). The State appealed.
The Sixth Circuit acknowledged that "[f]ederal habeas petitioners facing the death penalty for state criminal convictions do not enjoy a constitutional right to competence." Carter v. Bradshaw, 644 F.3d 329, 332 (2011). It nevertheless located a statutory right to competence in § 4241, relying, in part, on this Court's decision in Rees v. Peyton, 384 U.S. 312, 86 S.Ct. 1505, 16 L.Ed.2d 583 (1966) (per curiam)
The court concluded that "[a]nytime a capital habeas petitioner affirmatively seeks to forego his habeas petition, whether by action or inaction, ... a district court may employ section 4241." Id., at 334.
The court therefore amended the District Court's judgment and ordered that Carter's petition be stayed indefinitely with respect to any claims that required his assistance. Id., at 336-337. Judge Rogers dissented, arguing that there was no constitutional or statutory basis for the court's decision. Id., at 337-342.
We granted certiorari to determine whether § 4241 provides a statutory right to competence in federal habeas proceedings. 565 U.S. ___, ___, 132 S.Ct. 1738, 182 L.Ed.2d 528 (2012).
Both the Ninth and Sixth Circuits have concluded that death row inmates pursuing federal habeas are entitled to a suspension of proceedings when found incompetent. The Ninth Circuit located this right in § 3599, while the Sixth Circuit located it in § 4241. Neither section provides such a right.
Section 3599(a)(2) guarantees federal habeas petitioners on death row the right to federally funded counsel.
It stands to reason that the benefits flowing from the right to counsel at trial could be affected if an incompetent defendant is unable to communicate with his attorney. For example, an incompetent defendant would be unable to assist counsel in identifying witnesses and deciding on a trial strategy. For this reason, "[a] defendant may not be put to trial unless he `"has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding ... [and] a rational as well as factual understanding of the proceedings against him."'" Cooper, supra, at 354, 116 S.Ct. 1373 (quoting Dusky v. United States, 362 U.S. 402, 80 S.Ct. 788, 4 L.Ed.2d 824 (1960) (per curiam)). Notwithstanding the connection between the right to competence at trial and the right to counsel at trial, we have never said that the right to competence derives from the right to counsel. We will not assume or infer that Congress intended to depart from our precedents and locate a right to competence in federal habeas proceedings within the right to counsel. "We normally assume that, when Congress enacts statutes, it is aware of relevant judicial precedent." Merck & Co. v. Reynolds, 559 U.S. ___, ___, 130 S.Ct. 1784, 1795, 176 L.Ed.2d 582 (2010).
The Ninth Circuit located a statutory right to competence in § 3599. 623 F.3d, at 1245 (citing Rohan, 334 F.3d 803, and Nash, 581 F.3d 1048). Because Rohan is the Ninth Circuit's controlling precedent, we briefly address that decision.
In Rohan, a habeas petitioner asserted a right to competency based both on the Due Process Clause and on 21 U.S.C. § 848(q)(4)(B) (2000 ed.). After discussing the history of the common law, which prohibited the indictment, trial and execution of mentally incompetent defendants,
Invoking the canon of constitutional avoidance, the Ninth Circuit gave the petitioner the practical benefit of a due process right to competence in federal habeas proceedings through its interpretation of § 848(q)(4)(B).
We are not persuaded by the Ninth Circuit's assertion that a habeas petitioner's mental incompetency could "eviscerate the statutory right to counsel" in federal habeas proceedings. Given the backward-looking, record-based nature of most federal habeas proceedings, counsel can generally provide effective representation to a habeas petitioner regardless of the petitioner's competence. Indeed, where a claim is "adjudicated on the merits in State court proceedings," 28 U.S.C. § 2254(d) (2006 ed.), counsel should, in most circumstances, be able to identify whether the "adjudication ... resulted in a decision that was contrary to, or involved an unreasonable application of, clearly established
Rohan also cited Rees I, 384 U.S. 312, 86 S.Ct. 1505, 16 L.Ed.2d 583, in support of its conclusion. 334 F.3d, at 815. In Rees I, a state inmate on death row filed a petition for a writ of habeas corpus in District Court, alleging that the state-court conviction violated his constitutional rights. 384 U.S., at 313, 86 S.Ct. 1505. The District Court denied his petition, and the Court of Appeals affirmed. Ibid. Shortly after Rees' counsel filed a petition for certiorari with this Court, Rees directed his counsel to withdraw the petition and to forgo any further proceedings. Counsel advised the Court that he could not accede to these instructions without a psychiatric evaluation of Rees, because there was some doubt as to Rees' mental competency. Ibid. In response, the Court directed the District Court to determine Rees' mental competence. Id., at 313-314, 86 S.Ct. 1505. After the District Court conducted a hearing and found Rees incompetent, the Court issued a one-sentence order directing that the petition for certiorari be "held without action." Rees v. Peyton, 386 U.S. 989, 87 S.Ct. 1310, 18 L.Ed.2d 333 (1967) (Rees II).
The Ninth Circuit concluded that "[t]he record in Rees II shows that incompetence is grounds for staying habeas proceedings." Rohan, supra, at 815. This conclusion is unwarranted. Rees I concerned whether an incompetent habeas petitioner may withdraw his certiorari petition, and it provides no clear answer even to that question. Likewise, the unique, one-sentence order in Rees II offered no rationale for the decision to hold Rees' petition. As a result, Rees offers no support for federal habeas petitioners seeking to stay district court proceedings or for the Ninth Circuit's opinions in Rohan, Nash, or this case.
Gonzales barely defends the Ninth Circuit's
For the foregoing reasons, we hold that § 3599 does not provide federal habeas petitioners with a "statutory right" to competence.
The Sixth Circuit reached the same conclusion as the Ninth Circuit but located the statutory right to competence during habeas proceedings in 18 U.S.C. § 4241. Relying largely on Rees I, the Sixth Circuit concluded that § 4241 provides a statutory right to competence. 644 F.3d, at 333. But as discussed, Part II-A, supra, Rees I did not recognize a statutory right to competence in federal habeas proceedings.
By its own terms, § 4241 applies only to trial proceedings prior to sentencing and "at any time after the commencement of probation or supervised release." Federal habeas proceedings, however, commence after sentencing, and federal habeas petitioners, by definition, are incarcerated, not on probation.
Furthermore, § 4241, like the rest of Title 18 generally, applies exclusively to federal defendants and probationers subject to prosecution by the United States. Carter is not, and does not claim to be, a federal defendant. Rather, he is a state prisoner challenging the basis of his conviction in a federal civil action. See Blair v. Martel, 645 F.3d 1151, 1155 (C.A.9 2011) ("By its own terms, § 4241 does not apply unless a federal criminal defendant is on trial or is released on probation").
Finally, § 4241(a) authorizes the district court to grant a motion for a competency determination if there is reasonable cause to believe that the defendant's mental incompetence renders him "unable to understand the nature and consequences of the proceedings against him or to assist properly in his defense." (Emphasis added.) See also § 4241(d).
We would address Carter's arguments in defense of the Sixth Circuit's decision, but, there are none. Carter's brief informed us that "[t]his Court need not consider the statutory argument with which the [petitioner's] brief begins — i.e., that there is no `statutory right' under 18 U.S.C. § 4241 to be competent in habeas proceedings." Brief for Respondent in No. 11-218, p. 15. Apparently, Carter found the Sixth Circuit's reasoning indefensible. We agree.
Both Gonzales and Carter argued at length in their briefs and at oral argument that district courts have the equitable power to stay proceedings when they determine that habeas petitioners are mentally incompetent.
In Gonzales' case, the District Court correctly found that all of Gonzales' properly exhausted claims were record based or resolvable as a matter of law, irrespective of Gonzales' competence.
In Carter's case, the District Court concluded that four of Carter's
It is unclear from the record whether Carter exhausted the fourth claim.
The same principle obtains in the context of competency-based stays. At some point, the State must be allowed to defend its judgment of conviction.
If a district court concludes that the petitioner's claim could substantially benefit from the petitioner's assistance, the district court should take into account the likelihood that the petitioner will regain competence in the foreseeable future. Where there is no reasonable hope of competence, a stay is inappropriate and merely frustrates the State's attempts to defend its presumptively valid judgment.
The judgment of the Ninth Circuit is reversed. We vacate the judgment of the
It is so ordered.