Supreme Court: 8th Amendment bars execution of prisoner with dementia

The State of Alabama set an execution date for prisoner who then asserted an Eight Amendment Claim because his mental condition, relating to a series of strokes, rendered him incapable of recollecting committing the crime for which he had been sentenced to die. The Alabama Circuit Court found that the  prisoner was competent to be executed. Certiorari was granted.

The Supreme Court, Justice Kagan, held that:

A mental disorder that leaves a prisoner without any memory of committing his crime does not necessarily preclude execution; dementia may preclude execution; and the Supreme Court was unsure whether the state court relied on an incorrect view of the law, i.e., that only delusions, and not dementia, could preclude execution, and thus, state court’s judgment was vacated, and the case remanded.

Eighth Amendment precludes executing a prisoner who has lost his sanity

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 (Ford v. Wainwright, 477 U.S. 399). The Court articulated the competency standard: A State may not execute 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.” (Panetti v. Quarterman, 551 U.S. 930,at 958–959)

Claiming that that dementia rendered him with no memory of the crime for which he was to be executed, Madison petitioned the state trial court for a stay of execution on the ground that he was mentally incompetent because 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. The State also claimed that Madison’s claims failed  we’re not impacted by the 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.

Loss of memory of the crime may affect the ability to understand why a person is being executed

Justice Kagan wrote that the Eighth Amendment may permit executing a prisoner even if he cannot remember committing his crime. Panetti addresses only a person’s comprehension of the State’s reasons for resorting to punishment, not his memory of the crime itself. And the one may exist without the other. Such memory loss, however, still may factor into the analysis Panetti demands. If that loss combines and interacts with other mental shortfalls to deprive a person of the capacity to comprehend why the State is exacting death as a punishment, then the Panetti standard will be satisfied.

Psychotic delusions not only basis for an Eighth Amendment Claim

Under Ford and Panetti, the Eighth Amendment may prohibit executing a prisoner even though he suffers from dementia or another disorder rather than psychotic delusions. The Panetti standard focuses on whether a mental disorder has had a particular effect; it has no interest in any precise cause. The pivotal factor in both Ford and Panetti were a prisoner’s “[in]comprehension of why he has been singled out” to die and and when that failure of understanding is present a judge must look beyond any given diagnosis

The case was was remanded to the state court for renewed consideration of Madison’s competency because it was unclear whet her the state court knew a person with dementia, and not psychotic delusions, might receive a stay of execution. Madison’s competency depends on whether he can reach a rational understanding of why the State wants to execute him.

Prisoner with no memory of the crime may still understand reason for death sentence

The Court held that person with no memory of the crime may still be able to form a rational understanding of the reasons for his death sentence and the Eight Amendment would not bar his execution. The Eighth Amendment applies to a prisoner suffering from dementia as well as one experiencing psychotic delusions. The Court directed that issue to the state court for further consideration in light of it’s opinion.

Madison v. Alabama, 139 S.Ct. 718 (Decided February 27, 2019)

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