Law School Case Brief
Madison v. Alabama - 139 S. Ct. 718 (2019)
Regarding whether the Eighth Amendment forbids execution whenever a prisoner shows that a mental disorder has left him without any memory of committing his crime, the United States Supreme Court thinks not, because a person lacking such a memory may still be able to form a rational understanding of the reasons for his death sentence.
Petitioner Vernon Madison was found guilty of capital murder and sentenced to death. While awaiting execution, he suffered a series of strokes and was diagnosed with vascular dementia. In 2016, Madison petitioned the state trial court for a stay of execution on the ground that he was mentally incompetent, stressing that he could not recollect committing the crime for which he had been sentenced to die. Alabama responded that Madison had a rational understanding of the reasons for his execution, even assuming he had no memory of committing his crime. And more broadly, the State claimed that Madison failed to implicate Ford and Panetti because both decisions concerned themselves with gross delusions, which Madison did not have. Following a competency hearing, the trial court found Madison competent to be executed. On federal habeas review, this Court summarily reversed the Eleventh Circuit’s grant of relief, holding that, under the “demanding” and “deferential standard” of the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), “[n]either Panetti nor Ford ‘clearly established’ that a prisoner is incompetent to be executed” because of a simple failure to remember his crime. But the Court “express[ed] no view” on the question of Madison’s competency outside of the AEDPA context. When Alabama set a 2018 execution date, Madison returned to state court, arguing once more that his mental condition precluded the State from going forward. The state court again found Madison mentally competent.
Did the Eighth Amendment prohibit executing Madison, a state prisoner who had been diagnosed with vascular dementia, merely because he could not remember committing his crime?
The Supreme Court of the United States vacated the Alabama trial court's judgment and remanded the matter to that court for further proceedings. The Court ruled, inter alia, that the Eighth Amendment did not prohibit executing a state prisoner such as Madison who had been diagnosed with vascular dementia merely because he could not remember committing his crime. A person lacking memory of his crime might yet rationally understand why the State sought to execute him, and if so, the Eighth Amendment would pose no bar to his execution. The Court also ruled that if a prisoner could not reach a rational understanding of why the State wanted to execute him, the Eighth Amendment would prohibit executing him even though he suffered from dementia rather than psychotic delusions. Because the Court was uncertain whether the state court's decision was tainted by legal error, remand was necessary for renewed consideration of Madison's competency, that is, whether he could reach a rational understanding of why the State wanted to execute him.
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