Madison v. Alabama, 139 S. Ct. 718

Vernon Madison was convicted of capital murder (1985) and sentenced to death; decades later he suffered strokes and was diagnosed with vascular dementia with significant memory loss.
Madison sought stays in state court (2016, 2018), arguing dementia and amnesia rendered him incompetent to be executed under the Eighth Amendment.
Experts conflicted: Madison’s expert found retrograde amnesia and inability to grasp the State’s reasoning; the State’s expert found no psychosis or delusions and opined Madison understood his legal situation.
The Alabama trial court denied relief (2016 and a brief 2018 order), finding Madison competent; the Eleventh Circuit granted habeas relief but the Supreme Court summarily reversed on AEDPA grounds in Dunn v. Madison.
On direct review (no AEDPA deference), the Supreme Court considered whether (1) memory loss alone bars execution under Ford/Panetti, and (2) whether dementia (vs. psychotic delusions) can satisfy those precedents. The Court remanded for further state-court consideration of competency.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether mere lack of memory of the crime bars execution	Madison: amnesia prevents rational comprehension of the reason for punishment, so Eighth Amendment forbids execution	Alabama: memory loss alone does not defeat Panetti; Madison is not delusional and thus not protected	Memory loss alone does not bar execution under Panetti; only if memory loss, combined with other deficits, prevents a rational understanding will relief lie
Whether dementia (non‑delusional disorders) can support a Ford/Panetti claim	Madison: dementia can impair capacity to rationally understand the State’s reason and thus can bar execution	Alabama: Panetti and Ford concern gross delusions/psychosis, not dementia; dementia cannot suffice absent delusions	Dementia can, depending on its effect; Panetti focuses on the effect (inability to rationally understand), not a particular diagnosis
Whether the state court’s competency rulings were legally adequate	Madison: state rulings may have relied on an incorrect legal view (that only delusions qualify), tainting the decision	Alabama: state court applied Panetti correctly; earlier 2016 opinion expressly found Madison had rational understanding	The Supreme Court was not confident the 2018 order avoided the legal error; vacated and remanded for renewed competency proceedings ensuring Panetti’s standard is applied (and record supplemented if needed)

Ford v. Wainwright, 477 U.S. 399 (1986) (Eighth Amendment forbids executing persons who have lost sanity and cannot comprehend punishment)
Panetti v. Quarterman, 551 U.S. 930 (2007) (competency standard: prisoner must have a rational understanding of the State’s rationale for execution)
Dunn v. Madison, 583 U.S. _ (2017) (per curiam) (on AEDPA review, neither Ford nor Panetti clearly established that amnesia alone renders a prisoner incompetent to be executed)