WASHINGTON (CN) – The Supreme Court opened a window Wednesday for a death-row prisoner in Texas to fund an investigation of his mental health history.
Though the provision of funding for certain services is guaranteed under federal law for financially strapped individuals who face the prospect of a death sentence, the dispute at issue arose from language in the statute that says the services must be “reasonably necessary.”
Death-row inmate Carlos Manuel Ayestas argued that the Fifth Circuit employed too rigorous a standard in requiring that individuals seeking funding for such services show that they have a “substantial need.”
The U.S. Supreme Court was unanimous Wednesday in siding with Ayestas.
“The difference between ‘reasonably necessary’ and ‘substantially need[ed]’ may be small, but the Fifth Circuit exacerbated the problem by invoking precedent to the effect that a habeas petitioner seeking funding must present ‘a viable constitutional claim that is not procedurally barred,’” Justice Samuel Alito wrote for the court.
Alito went on to explain that the Fifth Circuit’s rule is too restrictive under precedent from the 2013 case Trevino v. Thaler.
“Trevino permits a Texas prisoner to overcome the failure to raise a substantial ineffective-assistance claim in state court by showing that state habeas counsel was ineffective, and it is possible that investigation might enable a petitioner to carry that burden,” Alito wrote. “In those cases in which funding stands a credible chance of enabling a habeas petitioner to overcome the obstacle of procedural default, it may be error for a district court to refuse funding.”
Though courts have discretion in assessing funding requests, Alito emphasized that “proper application of the ‘reasonably necessary’ standard thus requires courts to consider the potential merit of the claims that the applicant wants to pursue, the likelihood that the services will generate useful and admissible evidence, and the prospect that the applicant will be able to clear any procedural hurdles standing in the way.”
“To be clear, a funding applicant must not be expected to prove that he will be able to win relief if given the services he seeks,” the 19-page opinion continues. “But the ‘reasonably necessary’ test requires an assessment of the likely utility of the services requested, and §3599(f) cannot be read to guarantee that an applicant will have enough money to turn over every stone.”
Alito noted that the state presented an alternative argument: “that whatever ‘reasonably necessary’ means, funding is never ‘reasonably necessary’ in a case like this one, where a habeas petitioner seeks to present a procedurally defaulted ineffective-assistance-of-trial-counsel claim that depends on facts outside the state-court record.”
Texas says whatever fruits an investigation for Ayestas bears “would be inadmissible in a federal habeas court,” but Alito said it is up to the Fifth Circuit to consider this argument on remand.
Justice Ruth Bader Ginsburg joined a concurring opinion by Justice Sonia Sotomayor meanwhile that says there should be little doubt on remand that Ayestas has satisfied the statutory standard.
“The troubling failures of counsel at both the trial and state postconviction stages of Ayestas’ case are exactly the types of facts that should prompt courts to afford investigatory services to ensure that trial errors that go to a ‘bedrock principle in our justice system’ do not go unaddressed,” the 11-page dissent concludes.
Ayestas was convicted in 1997 of a brutal home invasion where 67-year-old Houston woman Santiaga Paneque was bound with duct tape and electrical cord, beaten and strangled.
Police were led to Ayestas two weeks later by a man whom Ayestas shared details of the murder before passing out drunk.
For months leading up to the trial, Ayestas refused to let defense counsel contact his family who were living in Honduras.
After his conviction, however, Ayestas was diagnosed with schizophrenia. He argued that his attorneys overlooked evidence that he was mentally ill and had a history of drug and alcohol abuse.