Demosthenes v. Baal - 495 U.S. 731 (1990)
U.S. Supreme Court
Demosthenes v. Baal, 495 U.S. 731 (1990)
Demosthenes v. Baal
Decided June 3, 1990
495 U.S. 731
Thomas Baal, after being examined by three psychiatrists who found him competent to stand trial, pleaded guilty to first-degree murder and robbery and was sentenced to death by a Nevada court. The State Supreme Court affirmed. Subsequently, he withdrew his request for state postconviction relief, testifying at an evidentiary hearing to determine his competency that he did not want to continue the proceedings and that he was aware of his impending execution and the reason for it. The court reviewed the psychiatrists' reports and other evidence and held that Baal was sane and had made an intelligent waiver of his right to pursue postconviction relief. A few hours before his scheduled execution, Baal's parents, applicants here, filed a petition for federal habeas corpus relief as his "next friend," contending that he was not competent to waive federal review. The District Court denied their application for a stay of execution, holding that it had no jurisdiction to entertain the petition. It found that, based on the record before the state court, Baal was legally competent, and it determined that a newly submitted affidavit by a nonexamining psychiatrist, which questioned Baal's competency, was conclusory and insufficient to warrant a psychiatric hearing or examination. The Court of Appeals reversed, ruling that applicants had made a minimum showing of Baal's incompetence warranting a basis for a full evidentiary hearing by the District Court.
Held: No adequate basis for the exercise of federal power exists. The prerequisite for "next friend" status -- that the real party in interest unable to litigate his own cause due to mental incapacity -- has not been satisfied. The state court's factual conclusion that Baal had intelligently waived his right to pursue postconviction relief was fairly supported by the record and, thus, is binding on a federal habeas court, see Maggio v. Fulford, 462 U. S. 111. However, the Court of Appeals, rather than relying exclusively on the nonexamining psychiatrist's affidavit to show that Baal might have become incompetent since the state court hearing, based its determination on the same evidence that had been before the state court. As there was no evidentiary basis for the Court of Appeals' conclusion that the District Court erred in declining to conduct an evidentiary hearing, the stay the court granted did not reflect the presence of substantial grounds upon which relief could be granted.