Colleen Mary Rohan, Ex Rel. Oscar Gates v. Jeanne Woodford, Warden

We decide whether a district court must stay capital habeas proceedings during a petitioner’s incompetence.

I

Oscar Gates was sentenced to death for murdering Lonnie Stevenson in 1979. Gates belonged to a forgery ring run by the Stevenson family, and became embroiled in a dispute over his cut of the proceeds during which a Stevenson family member shot him in the leg. Gates then went to the Stevensons’ house with a gun and met two family members, Lonnie and Maurice, in the yard. Gates killed Lonnie and wounded Maurice. Maurice claims Gates ordered them to hand over their jewelry and then shot them both. Gates claims he fired only after another family member showed up wielding a gun.

The State charged Gates with murder, robbery and other offenses. The jury convicted on all counts and found the special circumstance of murder in connection with a robbery, making Gates eligible for the death penalty. During the penalty phase, the State introduced evidence of Gates’s prior convictions for robbery, rape and kidnaping. It also presented evidence of a prior assault and robbery of two women that had resulted in one’s death, a crime for which Gates was later convicted. The…