Smith's Criminal Case Compendium

Smith's Criminal Case Compendium

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This compendium includes significant criminal cases by the U.S. Supreme Court & N.C. appellate courts, Nov. 2008 – Present. Selected 4th Circuit cases also are included.

Jessica Smith prepared case summaries Nov. 2008-June 4, 2019; later summaries are prepared by other School staff.

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E.g., 09/22/2021
E.g., 09/22/2021

If a defendant with no memory of his crime rationally understands why the State seeks to execute him, the Eighth Amendment does not bar execution; if a defendant with dementia cannot rationally understand the reasons for his sentence, it does. What matters, explained the Court, is whether a person has a “rational understanding,” not whether he has any particular memory or any particular mental illness.

            The Court noted that in Ford v. Wainwright, 477 U. S. 399 (1986), it held that the Eighth Amendment’s ban on cruel and unusual punishments precludes executing a prisoner who has “lost his sanity” after sentencing. It clarified the scope of that category in Panetti v. Quarterman by focusing on whether a prisoner can “reach a rational understanding of the reason for [his] execution.” Here, Vernon Madison killed a police officer in 1985. An Alabama jury found him guilty of capital murder and he was sentenced to death. In recent years, Madison’s mental condition sharply deteriorated. He suffered a series of strokes, including major ones in 2015 and 2016. He was diagnosed with vascular dementia, with attendant disorientation and confusion, cognitive impairment, and memory loss. Madison claims that he can no longer recollect committing the crime for which he has been sentenced to die. After his 2016 stroke, Madison petitioned the trial court for a stay of execution on the ground that he had become mentally incompetent, citing Ford and Panetti. The trial court found Madison competent to be executed. Madison then unsuccessfully sought federal habeas corpus relief. When Alabama set an execution date in 2018, Madison returned to state court arguing again that his mental condition precluded the State from going forward, noting, in part, that he suffered further cognitive decline. The state court again found Madison mentally competent. The U.S. Supreme Court agreed to review the case.

            The Court determined that a person lacking memory of his crime may yet rationally understand why the State seeks to execute him; if so, the Eighth Amendment poses no bar to his execution. It explained: “Assuming, that is, no other cognitive impairment, loss of memory of a crime does not prevent rational understanding of the State’s reasons for resorting to punishment. And that kind of comprehension is the Panetti standard’s singular focus.” It continued, noting that a person suffering from dementia or a similar disorder, rather than psychotic delusions, may be unable to rationally understand the reasons for his sentence; if so, the Eighth Amendment does not allow his execution. What matters, it explained, “is whether a person has the ‘rational understanding’ Panetti requires—not whether he has any particular memory or any particular mental illness.” The Court continued, noting that the “standard has no interest in establishing any precise cause: Psychosis or dementia, delusions or overall cognitive decline are all the same under Panetti, so long as they produce the requisite lack of comprehension.” Ultimately, the Court returned the case to the state court for renewed consideration of Madison’s competency, instructing:

In that proceeding, two matters disputed below should now be clear. First, under Ford and Panetti, the Eighth Amendment may permit executing Madison even if he cannot remember committing his crime. Second, under those same decisions, the Eighth Amendment may prohibit executing Madison even though he suffers from dementia, rather than delusions. The sole question on which Madison’s competency depends is whether he can reach a “rational understanding” of why the State wants to execute him. Panetti, 551 U. S. at 958.

In a per curiam decision in this capital murder case decided under the Antiterrorism and Effective Death Penalty Act of 1996, the Court held that the state court did not unreasonably apply the law when it determined that the defendant was competent to be executed. The defendant was sentenced to death in an Alabama court. As his execution neared, the defendant petitioned the trial court for a suspension of his death sentence, arguing that due to several recent strokes, he had become incompetent to be executed. At a hearing on the matter, a court appointed psychologist noted the defendant’s significant post-stroke decline but testified that he understood the posture of his case and that the State was seeking retribution against him for his criminal act. A defense psychologist testified that the defendant’s strokes rendered him unable to remember numerous events that had occurred in the past. However, he found that the defendant was able to understand the nature of the pending proceeding, what he was tried for, that he was in prison because of murder, that Alabama was seeking retribution for that crime, and the sentence, specifically the meaning of a death sentence. The defense witness also opined that the defendant does not understand the act he is being punished for because he cannot recall the sequence of events from the offense through the trial and believes that he “never went around killing folks.” After the trial court denied the defendant’s petition, the defendant pursued federal habeas proceedings. The federal district court denied the defendant’s petition and the Eleventh Circuit reversed. That court found that because the defendant has no memory of his capital offense it inescapably follows that he does not rationally understand the connection between his crime and his execution. On that basis, the federal appellate court held that the trial court’s conclusion that the defendant is competent to be executed was plainly unreasonable. The Court disagreed. Reviewing its prior case law, the Court concluded that those decisions did not clearly establish that a prisoner is incompetent to be executed because of a failure to remember his commission of the crime, as distinct from the failure to rationally comprehend the concepts of crime and punishment as applied in his case. Thus, the state court did not unreasonably apply Supreme Court law when it determined that the defendant was competent to be executed because, notwithstanding his memory loss, he recognizes that he will be put to death as punishment for the murder he was found to have committed.

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