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01/08/2013

Ryan v. Valencia Gonzales: Another Win for Statutory Textualism
Michael Ramsey

Today's Supreme Court opinion in Ryan v. Valencia Gonzales may not get much attention but it's worth noting as another unanimous win for textualism in statutory interpretation.  The question was whether a state prisoner's federal habeas corpus petition must be stayed when he is adjudged incompetent and thus unable to assist his lawyers.  Panels of the Sixth and Ninth Circuits held for the prisoner, on reasonable equitable grounds but only by considerable stretches of the applicable statute, the Antiterrorism and Effective Death Penalty Act of 1996.  The Court, per Justice Thomas and in accord with the arguments of the U.S. executive branch, reversed.  Notably, a prior Supreme Court case, Rees v. Peyton, provided some plausible authority for the prisoner, but the Court's opinion brushed it aside.  (SCOTUSblog's analysis is here).  While the result shouldn't be surprising, the Court's unanimity fits a broader trend.