Recently, the United States Supreme Court addressed in Ryan v. Gonzales “whether the incompetence of a state prisoner requires suspension of the prisoner’s federal habeas corpus proceedings.” In a unanimous decision, the Court held that “the Courts of Appeals for the Ninth and Sixth Circuits both erred in holding that district courts must stay federal habeas proceedings when petitioners are adjudged incompetent.” The decision leaves unanswered questions with regard to a petitioner’s ability to protect himself from ineffective or incompetent counsel both before and during the habeas proceeding.