86 U.S.L.W. 3225
U.S.2017Background
- Vernon Madison was convicted of capital murder in Alabama for the 1985 killing of Officer Julius Schulte and sentenced to death.
- By 2016 Madison had suffered multiple strokes producing vascular dementia and severe memory loss; he could not remember the offense but understood he was imprisoned for "murder" and that Alabama sought to execute him.
- At a state-court competency hearing, two psychologists testified: the State’s expert concluded Madison had a rational understanding of his punishment; Madison’s expert emphasized his extensive memory loss and opined he did not recall the offense though he understood the proceedings and sentence.
- The state trial court denied Madison’s motion to suspend execution under Ford/Panetti; the District Court denied federal habeas relief under AEDPA, finding the state court’s ruling reasonable.
- The Eleventh Circuit reversed, holding that Madison’s inability to remember the crime rendered him incompetent under Panetti; the Supreme Court granted certiorari and reversed the Eleventh Circuit.
Issues
| Issue | Plaintiff's Argument (Madison) | Defendant's Argument (Dunn/State) | Held |
|---|---|---|---|
| Whether memory loss of the offense alone renders a prisoner incompetent to be executed under the Eighth Amendment | Memory loss severs the connection between crime and punishment so Madison cannot rationally understand why he will be executed | Competency requires a rational understanding of the link between crime and punishment; Madison does understand he was convicted of murder and will be executed for it despite memory loss | The state court reasonably concluded memory loss alone does not establish incompetency under Ford/Panetti; Madison is not entitled to habeas relief under AEDPA |
| Whether the state court unreasonably applied clearly established federal law (AEDPA standard) | The state court’s conclusion conflicts with Panetti and Ford given Madison’s lack of memory | The state court applied Panetti/Ford correctly and its factual findings were reasonable | The Supreme Court reversed the Eleventh Circuit, finding no unreasonable application of clearly established law and no unreasonable factual determination |
Key Cases Cited
- Ford v. Wainwright, 477 U.S. 399 (Eighth Amendment bars executing the insane; competence requires comprehension of punishment)
- Panetti v. Quarterman, 551 U.S. 930 (Eighth Amendment forbids execution of prisoners who lack rational understanding of why they are to be executed)
- Harrington v. Richter, 562 U.S. 86 (AEDPA deference: state-court decisions must be more than incorrect to warrant federal habeas relief)
- Madison v. Commissioner, Ala. Dep’t of Corrections, 851 F.3d 1173 (11th Cir. 2017) (appellate decision reversing state court and finding incompetency)
- Ex parte Madison, 718 So. 2d 104 (Ala. 1998) (state-court criminal conviction and sentencing)
- In re Medley, 134 U.S. 160 (historical discussion of prolonged detention and cruelty of delay)