Madison v. Alabama

The Eighth Amendment permits execution of a prisoner who cannot remember committing the crime. Panetti v. Quarterman requires only the ability of the prisoner to comprehend the State's reason for the punishment and that judges look downstream to determine whether a specific mental condition may limit the prisoner's ability to comprehend the State's rationale at any time leading up to his execution.

While awaiting execution for capital murder, Petitioner received a diagnosis of vascular dementia rendering him unable to remember committing the crime. He petitioned the trial court for a stay of execution arguing mental incompetence under Ford v. Wainwright, 477 U.S. 399 (1986), and Panetti v. Quarterman, 551 U.S. 930 (2007). Ford precludes execution of a prisoner who has lost sanity post-sentencing and Panetti precludes execution if a mental illness prevents a prisoners’ rational understanding of the State’s justification for the execution. The trial court found Petitioner competent. On federal habeas review, the United States Supreme Court reversed the Eleventh Circuit’s grant of relief holding that neither Ford nor Panetti clearly established that incompetence may be determined by failure to remember the crime. Petitioner’s execution was rescheduled, he made the same argument to the trial court, and was again found competent. On direct review, the Court held that the Eighth Amendment permits execution of a prisoner who cannot remember committing the crime. Panetti requires only comprehension of the State’s reasons for the punishment and for judges to determine whether the prisoner’s mental condition may limit comprehension in the future. The Court remanded, directing the lower court to make a competency determination consistent with its holding. VACATED and REMANDED.