Madison v. Alabama

Brief Filed: 5/18
Court: United States Supreme Court
Year of Decision: 2019

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Whether a state may execute a prisoner whose mental disability leaves him without memory of his commission of the capital offense, and whether the Eighth Amendment bars execution of a prisoner whose medical condition prevents him from remembering the crime for which he was convicted or understanding the circumstances of his scheduled execution.

Competency; Death Penalty

The petitioner in Madison (Vernon Madison) has been on death row for over 30 years. In that time, he suffered numerous strokes and was diagnosed with vascular neurological disorder, or vascular dementia. As a result, he no longer remembers the offense for which he was sentenced to die, nor his trial or arrest.

APA (as it did in Panetti) addresses the nature of dementia and how dementia affects a prisoner’s ability to be “aware[] of why” he is being punished, as well as the role that mental-health professionals can play in assisting with competency determinations. A prisoner with vascular dementia lacks a “rational understanding” of the reasons for his execution; although he may have (as the prisoner in Panetti had) “awareness of what the State has claimed as a reason” for his execution, he does not truly “understand[] the reason the death penalty is being applied in [his] own case.” The joint APA, American Bar Association and American Psychiatric Association policy statement states, “If, after challenges to the validity of the conviction and death sentence have been exhausted and execution has been scheduled, a court finds that a prisoner has a mental disorder or disability that significantly impairs his or her capacity to understand the nature and purpose of the punishment, or to appreciate the reason for its imposition in the prisoner’s own case, the sentence of death should be reduced to the sentence imposed in capital cases when execution is not an option.” It further states that dementia is “very similar to mental retardation in [its] impact on intellectual and adaptive functioning,” and that the only characteristic differentiating these disabilities is age of onset.

In a 5-3 decision, the Supreme Court vacated and remanded the lower court’s decision in this case. The Court said that the two questions before it were answered by its prior precedent (Ford and Panetti) and by the parties’ concessions before the Court. Specifically, the Court said that a person’s inability to remember his crime does not make him categorically ineligible for execution, while the fact that someone suffers from dementia rather than the disabilities in Ford and Panetti did not automatically take him outside those cases (i.e., did not automatically make him constitutionally eligible for execution). The key, the Court reiterated, is simply whether someone has a rational understanding of why he is to be executed. The Court said the lower court should address that question again in light of its (the Supreme Court’s) clarification of the law.