The Supreme Court on Wednesday declined to block the execution of Tracy Beatty, who was convicted and sentenced to death for the 2003 murder of his mother. Beatty, 61, is scheduled to be executed in Texas on Wednesday evening.
In the months leading up to his execution date, Beatty’s lawyers hired experts to evaluate his mental health, but state prison officials would not remove Beatty’s handcuffs for the experts’ evaluations. Two federal courts rejected Beatty’s argument that they could order prison officials to allow the evaluations to go ahead without handcuffs. Beatty had urged the justices to put his execution on hold to give them time to review that holding, but in a brief order with no recorded dissents, the justices declined to intervene.
The dispute began earlier this year, when Beatty had a severe mental health crisis. His attorneys scheduled in-person evaluations for Beatty for use in his clemency efforts and to determine whether he had a claim under Ford v. Wainwright, the landmark 1986 decision holding that the Eighth Amendment’s ban on cruel and unusual punishment bars the execution of an inmate who is mentally incompetent.
Prison officials refused to remove Beatty’s handcuffs for the evaluations without a court order, and a federal district court turned down Beatty’s request for that order. Beatty’s lawyers relied on 18 U.S.C. § 3599, which gives district courts the power to authorize services that “are reasonably necessary for the representation of the defendant.” But the district court ruled that although Section 3599 provides money for lawyers and services for death-row inmates, it does not give federal courts the power to compel states to allow the services to be delivered. The U.S. Court of Appeals for the 5th Circuit upheld that ruling.
Beatty’s lawyers argued that although they went ahead with the evaluations, their experts were limited in what they could do because Beatty was handcuffed. However, they note, the neuropsychiatrist who examined Beatty concluded that Beatty is “clearly psychotic” and lives in a “complex delusional world,” while a neuropsychologist confirmed that Beatty has cognitive deficits.
Beatty came to the Supreme Court on Monday, asking the justices to put his execution on hold and review the 5th Circuit’s decision. He argued that allowing his execution to go forward without the chance to conduct the full battery of evaluations “sanctions a sentence that may have been commuted.” More broadly, he added, allowing the lower court’s ruling to stand would be inconsistent with both the Supreme Court’s case law and the purpose of Section 3599, which he said is to ensure that death-row inmates receive meaningful representation and services.
The state countered that Section 3599 only gives federal district courts limited power over issues “related to appointing counsel and authorizing funding for indigent inmates.” In particular, the state wrote, the purpose of the statute is to address “financial hurdles to obtaining services, not hypothetical correctional facilities’ policies that may render an inmate unable to obtain the psychological evaluation of choice.” And in any event, the state added, Beatty waited too long to seek the mental-health evaluations, and the state dismissed his current efforts as merely a “delay tactic.”
This post is also published on SCOTUSblog.