Taray Morris v. Tony Malfi

MEMORANDUM

Taray Morris appeals from the district court’s judgment, denying Morris’s habeas petition. We have jurisdiction under 28 U.S.C. § 2253 , and we affirm.

Morris first alleges that he was mentally incompetent at the time of his plea, conviction, and sentencing, in violation of his due process rights. As the last reasoned decision of the state court dismissed his claim on procedural grounds, we review the competency claim de novo.

The Due Process Clause of the Fourteenth Amendment prohibits the criminal prosecution of a defendant while he is legally incompetent. See Drope v. Missouri, 420 U.S. 162, 172 , 95 S.Ct. 896 , 43 L.Ed.2d 103 (1975). A defendant is competent to stand trial if he “has sufficient present ability to consult with his lawyer with a reasonable degree of rational understanding” and “has a rational as well as factual understanding of the proceedings against him.” Id. (quoting Dusky v. United States, 362 U.S. 402, 402 , 80 S.Ct. 788 , 4 L.Ed.2d 824 (1960) (internal quotation marks omitted)). The same standard applies to a defendant’s competency to plead guilty and waive counsel for the plea. See Godinez v. Moran, 509 U.S. 389, 398 , 113 S.Ct. 2680 , 125…