John Ferguson v. Secretary, Florida Department of Corrections
2013 U.S. App. LEXIS 10161
| 11th Cir. | 2013Background
- Panetti v. Quarterman governs execution competency but not a precise standard; Panetti allowed development of rational understanding on remand.
- Ferguson alleges mental incompetence to be executed under Panetti; record shows he has a mental illness but understands he will die due to murders.
- Crimes: eight murders (Carol City), two additional murders (Hialeah); victims bound, shot in the back, some survivors; extensive graphic evidence described.
- Prior adjudications found Ferguson competent to stand trial, and later to proceed in post-conviction matters; multiple state and federal determinations over decades.
- Governor issued execution warrant; 2012 Florida competency proceedings found Ferguson had rational understanding of death penalty and why imposed; Florida Courts upheld competency.
- Federal habeas petition filed (28 U.S.C. § 2254); district court stayed briefly but denied on merits; Eleventh Circuit affirmed denial of relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Florida's competency standard as applied violated Panetti | Ferguson contends Provenzano/Panetti require rational understanding beyond mere awareness. | Florida courts applied a rational-understanding standard consistent with Panetti’s remand guidance. | Not contrary/unreasonable under AEDPA; Florida standard affirmed. |
| Whether the Florida courts unreasonably applied Panetti to Ferguson’s delusions | Delusions (Prince of God) render Ferguson unable to rationally understand execution. | Record shows Ferguson understands execution and its relation to crimes; delusions do not negate rational understanding. | No unreasonable application; substantial evidence supports rational understanding. |
| Whether AEDPA deference requires reversing state-court competency ruling | State court misapplied Panetti and misread facts; result unreasonable. | AEDPA deferential standard applies; fairminded judges could differ. | AEDPA deference preserved; no reversal. |
| Whether Ferguson received a fair evidentiary hearing on competency | Argues due process was violated by state hearings. | Hearing satisfied Panetti and Ford; opportunity to present evidence and witnesses. | No due-process violation; hearing adequate. |
Key Cases Cited
- Panetti v. Quarterman, 551 U.S. 930 (U.S. 2007) (requires rational understanding, not mere awareness of state rationale)
- Ford v. Wainwright, 477 U.S. 399 (U.S. 1986) (established baseline for competency to be executed)
- Provenzano v. State, 760 So.2d 137 (Fla. 2000) (Florida rational-understanding approach to capital execution competency)
- Provenzano v. Moore, 744 So.2d 413 (Fla. 1999) (predecessor context for Provenzano framework)
- Ferguson v. State, 580 F.3d 1183 (11th Cir. 2009) (federal habeas affirmance of state competency ruling)