Madison v. Alabama

Justia Summary

In “Ford” the Supreme Court held that the Eighth Amendment’s ban on cruel and unusual punishments precludes executing a prisoner who has “lost his sanity” after sentencing; in “Panetti,” the Court prohibited execution of a prisoner whose “mental state is so distorted by a mental illness” that he lacks a “rational understanding” of “the State’s rationale for [his] execution.” Madison was convicted of murder and sentenced to death. He subsequently suffered several strokes and was diagnosed with vascular dementia. Madison sought a stay of execution, stressing that he could not recollect committing the crime. Alabama rejected his claim. The Supreme Court summarily reversed the Eleventh Circuit’s grant of habeas relief, holding that neither Panetti nor Ford clearly established that a prisoner is incompetent to be executed simply because of failure to remember his crime but otherwise expressed no view on Madison’s competency. Alabama set an execution date; a state court again found Madison competent.

The Supreme Court vacated. Under Ford and Panetti, execution may be permissible if the prisoner cannot remember committing his crime. Memory loss may, however, factor into the Panetti analysis to determine whether that loss interacts with other mental shortfalls to deprive a person of the capacity to comprehend why the state is exacting death as a punishment. The Eighth Amendment may prohibit executing a prisoner who suffers from dementia or another disorder rather than psychotic delusions. The Panetti standard focuses on whether a mental disorder has had a particular effect; not on establishing any precise cause. In evaluating competency, a judge must look beyond any given diagnosis to a downstream consequence. The Court remanded for renewed consideration of Madison’s competency by evaluation of whether he can reach a rational understanding of why the state wants to execute him.