Stanley v. Chappell

Background

Darren Cornelius Stanley, a condemned prisoner at California’s San Quentin State Prison, moved for an order requiring prison administrators to allow a hired videographer to enter the prison and record three 90-minute inmate practice-group sessions involving the 5% Nation of Gods and Earth. Stanley described himself as an “inmate facilitator” for those groups.

Stanley sought the recordings to support Claim Nineteen of his finalized federal petition. That claim alleges that he is permanently incompetent to be executed under Ford v. Wainwright. The federal case was stayed so Stanley could return to state court to exhaust certain unexhausted claims, and the opinion states that his state exhaustion petition remained pending before the Alameda County Superior Court.

Stanley argued that recordings of his interactions with other inmates would show whether statements about his beliefs reflected religious beliefs or grandiose delusional thinking. He relied on the All Writs Act, a federal law that can give courts authority to issue orders needed to preserve their ability to decide a case, and on the court’s earlier order preserving voir dire notes and records.

Analysis

The court distinguished the earlier preservation order. That order concerned tangible evidence already in existence that Stanley had shown could be destroyed and could not be replaced. The current request would require prison officials to permit an event to occur and be recorded, meaning it would create new evidence rather than preserve existing evidence. Stanley cited no authority allowing the court to order that affirmative conduct.

The court also held that the motion would fail even if treated as a request merely to preserve evidence. Applying a three-factor balancing test, the court considered: (1) the concern that the evidence might not continue to exist or remain reliable without an order; (2) the irreparable harm likely to result without preservation; and (3) the ability of the person or entity holding the evidence to maintain it.

The court found insufficient concern about the evidence’s continued existence or integrity because the relevant evidence—Stanley’s expression of his beliefs and understanding of death and the afterlife, or his alleged delusions—remained within his control. Although interactions with other inmates might provide helpful information, the court found no indication that recordings of those interactions were indispensable. Stanley had already explained his beliefs during interviews and examinations with experts, and the court stated that he presumably would remain able to do so.

The court further concluded that Stanley had not shown irreparable harm. It found no demonstrated prejudice from waiting until the state court allowed the requested discovery or until the federal court considered the issue after the stay ended. The court also found no threat that tangible, material, and irreplaceable evidence would be lost or destroyed beyond Stanley’s control.

Finally, the court characterized the motion as essentially a discovery request. It had previously recognized that discovery generally was not permissible in support of an unexhausted petition absent an extraordinary circumstance, and it found that Stanley had not shown such a circumstance. The court clarified that its earlier authorization of federal funds for a videographer did not decide whether Stanley was entitled to preserve evidence, conduct discovery, or obtain access for the videographer to secure prison areas.

Disposition

Judge Edward M. Chen denied Stanley’s Motion to Preserve Evidence of his Activities in the 5% Nation of Gods and Earth at San Quentin Prison, Docket No. 316. The order states that it disposes of Docket No. 316.