Madison v. Alabama

Madison v. Alabama
Argued October 2, 2018
Full case name Vernon Madison, Petitioner v. Alabama
Docket nos. 17-7505
Citations TBD U.S. ___ (more)
Questions presented

Consistent with the Eighth Amendment, and this Court's decisions in Ford and Panetti, may the State execute a prisoner whose mental disability leaves him without memory of his commission of the capital offense?

Do evolving standards of decency and the Eighth Amendment's prohibition of cruel and unusual punishment bar the execution of a prisoner whose competency has been compromised by vascular dementia and multiple strokes causing severe cognitive dysfunction and a degenerative medical condition which prevents him from remembering the crime for which he was convicted or understanding the circumstances of his scheduled execution?
Court membership
Chief Justice
John Roberts
Associate Justices
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Neil Gorsuch
Laws applied
U.S. Const. amend. VIII

Madison v. Alabama is a pending United States Supreme Court case regarding whether Eight Amendment to the United States Constitution prohibits executing a person for a crime they do not remember.

Background

Vernon Madison shot police officer Julius Schulte twice in the back of the head in Mobile, Alabama on April 1985. Schulte was mediating a domestic disturbance between Madison and his ex-girlfriend; Madison also shot and injured her. Madison is an inmate at Holman Correctional Facility and has been since September 1985.[1][2][3][4]

Three trials were held, as the convictions from the first two were overturned: the first because prosecutors unconstitutionally excluded black people from the jury and the second because they improperly introduced evidence. In the third trial, the jury decided on a sentence of life in prison but the judge overruled them and gave Madison a sentence of death in 1994.[1][3]

The execution was scheduled to occur on May 2016; the 11th Circuit Court of Appeals granted a stay on the day of the execution, which the Supreme Court upheld 4-4; Antonin Scalia had left a vacancy when he died a few months previously, and he would in all likelihood have voted to reverse the stay.[3][5][6]

In Dunn v. Madison on November 2017, the Supreme Court unanimously overturned a 2-1 decision by the Circuit Court who had stopped the execution on the basis that he "does not rationally understand the connection between his crime and his execution". The Circuit Court was overruling a state court decision that had denied Madison's petition on the basis that Supreme Court precedent only barred execution if he lacked "understanding he is being executed as punishment for a crime".[5][7] The Supreme Court did not rule on the merits of the case, but that under the Antiterrorism and Effective Death Penalty Act of 1996, which set the standard for which federal courts can overturn a lower court's decision, the Circuit Court overstepped its authority.[7]

The execution was scheduled for January 2018; the Supreme Court granted a stay 30 minutes before he was schedule to be executed, with Clarence Thomas, Samuel Alito, and Neil Gorsuch dissenting.[1][2][3][5]

Madison's health

Madison had severe strokes in 2015 and 2016, resulting in vascular dementia and him not remembering killing police officer Schulte in 1985.[3][5][8] He is blind and has suffered a significant mental decline; he only remembers the alphabet to the letter G and has slurred speech. However, according to the psychologist appointed by the court, he understands that he will be executed and the reason for that.[3][5]

Past precedent

In Ford v. Wainwright, the Supreme Court held in 1985 that executing the insane is not allowed due the Eight Amendment, and in Panetti v. Quarterman, they held in 2007 that to be sentenced to death an inmate must understand "the meaning and purpose of" his death sentence.[8][9]

Case

The Supreme Court decided to hear the case in February 2018.[3] Oral arguments were held on October 2, 2018.[4][9]

References

  1. 1 2 3 Almasy, Steve; Mayra, Cuevas (26 January 2018). "Supreme Court stays execution of Alabama inmate who lawyers say is not competent". CNN. Retrieved 27 September 2018.
  2. 1 2 Palmer, Evan (27 February 2018). "Inmate who spent 30 years on death row may be spared execution—as he can't remember carrying out the crime". Newsweek. Retrieved 27 September 2018.
  3. 1 2 3 4 5 6 7 Liptak, Adam (5 March 2018). "Too Old to Be Executed? Supreme Court Considers an Aging Death Row". The New York Times. Retrieved 27 September 2018.
  4. 1 2 Epps, Garrett (18 September 2018). "The Machinery of Death Is Back on the Docket". The Atlantic. Retrieved 27 September 2018.
  5. 1 2 3 4 5 "Supreme Court to hear case where man can't remember killing". Associated Press. 26 February 2018. Retrieved 27 September 2018.
  6. ↑ Stein, Kelsey (13 May 2016). "What's next for Alabama death row inmate Vernon Madison after execution was stayed?". AL.com. Retrieved 27 September 2018.
  7. 1 2 Barnes, Robert (6 November 2017). "Supreme Court won't stop execution of man who can't remember murder". Washington Post. Retrieved 27 September 2018.
  8. 1 2 "Justices consider whether a man with dementia may be put to death". The Economist. 6 October 2018. Retrieved 6 October 2018.
  9. 1 2 Howe, Amy (2 October 2018). "Argument analysis: A narrow victory possible for death-row inmate with dementia?". SCOTUSblog. Retrieved 5 October 2018.
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