Dunn v. Madison

A person who merely understands why they are being punished is competent to be executed although they do not remember the crime they committed.

Approximately thirty years ago, petitioner killed a police officer when he shot the officer twice at close range. The trial court sentenced the petitioner to execution. In 2016, petitioner filed a petition of habeas corpus claiming that his recent strokes rendered him incompetent to face execution. Testimony from two psychologists confirmed that while petitioner had no recollection of the events that led to his sentence, petitioner comprehended the result of a death sentence and understood why he was being punished.  The trial court found, following Ford v. Wainwright and Panetti v. Quarterman, that petitioner failed to carry his burden of proving that his mental illness deprived him of being able to rationally understand that his execution is punishment for a crime he committed. Petitioner then filed a petition for habeas corpus in federal district court that was denied. On appeal, the Eleventh Circuit reversed the lower court because it found that petitioner's lack of memory of the crime equated him to not understanding the link between the offense and his execution. The Supreme Court granted certiorari to decide whether a person that understands why they are being punished but cannot recall the actual crime is competent to be executed. The Court determined that the lower state court did not unreasonably apply the principles in Ford or Panetti because neither of those cases clearly establishes that competence requires an ability to remember the crime committed. REVERSED.