Vernon Madison v. Commissioner, Alabama Department of Corrections
851 F.3d 1173
| 11th Cir. | 2017Background
- Vernon Madison, a 66‑year‑old death‑row inmate, suffered multiple strokes (including a right thalamic infarct) producing vascular dementia, severe memory loss, slurred speech, blindness, immobility, and incontinence.
- After counsel alleged incompetency to be executed under Ford/Panetti, an Alabama trial court ordered evaluations and held a competency hearing.
- Two experts testified: Dr. John Goff (Madison’s expert) diagnosed major vascular neurocognitive disorder with retrograde amnesia and concluded Madison does not remember the murder and therefore lacks a rational understanding of why he is to be executed; Dr. Karl Kirkland (court‑appointed) found no malingering and focused on Madison’s ability to describe legal history and appeals, concluding Madison could rationally understand his sentence.
- The Alabama trial court credited Dr. Kirkland and found Madison competent; state law forecloses appellate review of that competency ruling.
- On federal habeas review under AEDPA, the Eleventh Circuit held the state court’s factual finding was unreasonable and that, applying Panetti de novo, Madison is incompetent to be executed because he lacks a rational understanding of the link between his crime and the punishment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Competency to be executed under the Eighth Amendment (Ford/Panetti) | Madison: strokes/dementia produced retrograde amnesia so he cannot rationally understand that he is being executed for the murder he committed. | State: Madison can describe his appeals and knows he is sentenced to death; thus he understands the reason for execution. | Held: Madison is incompetent — record shows unrebutted evidence he does not remember the crime and therefore cannot rationally connect it to his execution. |
| Whether state court’s competency finding was entitled to AEDPA deference | Madison: the state court unreasonably determined facts and failed to apply Panetti because it ignored dementia and memory loss. | State: trial court considered evidence and reasonably credited Dr. Kirkland; AEDPA deference should apply. | Held: The state court’s finding was an unreasonable determination of the facts and an unreasonable application of Panetti, so AEDPA deference is not owed and the court reviewed de novo. |
| Proper scope of Panetti’s ‘‘rational understanding’’ test | Madison: Panetti requires assessing the prisoner’s concept of reality and whether mental disorder prevents appreciation of the crime–punishment link (not just factual awareness). | State: Panetti does not categorically prohibit executing persons with dementia absent delusions; factual awareness may suffice. | Held: Panetti requires more than factual awareness; dementia that eliminates memory of the offense can render one incompetent. |
| Exhaustion / procedural posture (state review limitation) | Madison: Alabama law precludes appellate review of §15‑16‑23 rulings, so federal review was permissible and AEDPA still applies. | State: (argued below that exhaustion might be incomplete) | Held: District court correctly found available state remedies exhausted because Alabama statute makes trial judge’s ruling final. |
Key Cases Cited
- Ford v. Wainwright, 477 U.S. 399 (Eighth Amendment forbids executing the incompetent; requires awareness of punishment and reasons)
- Panetti v. Quarterman, 551 U.S. 930 (Eighth Amendment requires a prisoner to have a rational, not merely factual, understanding of the connection between his crime and his execution)
- Harrington v. Richter, 562 U.S. 86 (AEDPA gives state‑court rulings highly deferential standard)
- Ferguson v. Sec’y, Florida Dep’t of Corr., 716 F.3d 1315 (11th Cir.) (interpreting Panetti: competency inquiry focuses on understanding link between crime and punishment)