Madison v. Alabama

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Supreme Court of the United States
Madison v. Alabama
Term: 2018
Important Dates
Argument: October 2, 2018
Decided: February 27, 2019
Outcome
Alabama 13th Circuit Court vacated and remanded
Vote
5-3
Majority
Chief Justice John G. Roberts • Ruth Bader Ginsburg • Stephen Breyer • Sonia Sotomayor • Elena Kagan
Dissenting
Clarence Thomas • Samuel Alito • Neil Gorsuch

Madison v. Alabama is a case argued before the Supreme Court of the United States on October 2, 2018, during the court's 2018-2019 term. The case concerned an inmate’s mental fitness to be executed.

In a 5-3 opinion, the court vacated and remanded the Alabama 13th Circuit Court's ruling, holding that "the Eighth Amendment may permit executing a prisoner even if he cannot remember committing his crime, but it may prohibit executing a prisoner who suffers from dementia or another disorder rather than psychotic delusions," according to SCOTUSblog.[1][2][3]

HIGHLIGHTS
  • The case: Attorneys for Vernon Madison sought a stay of his execution in January 2018, arguing that he was mentally unfit to be executed. The state court disagreed and denied the stay. The U.S. Supreme Court agreed to hear the case and ordered a stay of execution until a ruling could be made in this case.
  • The issue: There are two issues in this case: (1) Whether, consistent with the Eighth Amendment, and the Supreme Court’s decisions in Ford v. Wainwright and Panetti v. Quarterman, a state may execute a prisoner whose mental disability leaves him with no memory of his commission of the capital offense; and (2) whether 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 that prevents him from remembering the crime for which he was convicted or understanding the circumstances of his scheduled execution.[3]
  • The outcome: The court vacated and remanded the decision of the Alabama 13th Circuit Court, holding that "the Eighth Amendment may permit executing a prisoner even if he cannot remember committing his crime, but it may prohibit executing a prisoner who suffers from dementia or another disorder rather than psychotic delusions," according to SCOTUSblog.[2][3]


    • You can review the lower court's opinion here.[4]

    Timeline

    The following timeline details key events in this case:

    • February 27, 2019: U.S. Supreme Court vacated and remanded the decision of the Alabama 13th Circuit Court
    • October 2, 2018: Oral argument
    • February 26, 2018: U.S. Supreme Court agreed to hear case
    • January 18, 2018: Petition filed with U.S. Supreme Court
    • January 16, 2018: Alabama 13th Circuit Court denied Madison's petition for a stay of execution

    Background

    In April 1985, Vernon Madison shot and killed Mobile police officer Cpl. Julius Schulte during a domestic disturbance call. Madison was convicted of murder and sentenced to death three times—1985, 1990, and 1994. The first two convictions were overturned on appeal. At his final conviction, the judge overruled the jury's recommendation of a life sentence and issued a death sentence.[5]

    Madison was scheduled for execution in May 2016, but at a competency hearing earlier that year he claimed that he could no longer remember the crime he committed or even that he was on death row after suffering a number of strokes that impacted his mental capacity. A court-appointed psychologist said that while Madison had "significant body and cognitive decline as a result of strokes," he understood what he was convicted of and the proposed punishment. The state attorney general argued that understanding was enough to allow for execution. The court agreed, but the U.S. Court of Appeals for the Eleventh Circuit issued a stay pending an appeal.[6] In a deadlocked ruling, the U.S. Supreme Court upheld the appellate court's stay of execution.[5] In November 2017, the Eleventh Circuit ruled in favor of Madison, finding he was incompetent to be executed. The Supreme Court overturned that decision the same month, which cleared him for execution.[7]

    Madison's execution was scheduled for January 25, 2018. A hearing before the Alabama 13th Circuit Court on January 16 denied a request to stay the execution. In its ruling, the court said that "[t]he Defendant did not provide a substantial threshold showing of insanity, a requirement set out by the United States Supreme Court, sufficient to convince this Court to stay the execution."[4] Madison filed an appeal with the U.S. Supreme Court on January 18, and the court issued a stay of execution on January pending the outcome of the appeal on January 25. Justices Thomas, Alito, and Gorsuch voted to deny the stay. The court agreed to hear the case on February 26.[3]

    Questions presented

    The petitioner presented the following questions to the court:[1]

    Questions presented:
    • 1. 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?
    • 2. 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?

    Audio

    • Audio of oral argument:[8]

    Transcript

    • Read the oral argument transcript here.

    Outcome

    Decision

    Justice Elena Kagan delivered the 5-3 opinion of the court. The court vacated and remanded the decision of the Alabama 13th Circuit Court, holding that "the Eighth Amendment may permit executing a prisoner even if he cannot remember committing his crime, but it may prohibit executing a prisoner who suffers from dementia or another disorder rather than psychotic delusions," according to SCOTUSblog.[2][3]

    Opinion

    In her opinion for the court, Justice Kagan, who was joined by Chief Justice John G. Roberts and Justices Ruth Bader Ginsburg, Stephen Breyer, and Sonia Sotomayor, wrote,

    “ 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 answering that question—on which we again express no view, see supra, at 6—the state court may not rely on any arguments or evidence tainted with the legal errors we have addressed. And because that is so, the court should consider whether it needs to supplement the existing record. Some evidence in that record, including portions of the experts’ reports and testimony, expressly reflects an incorrect view of the relevance of delusions or memory; still other evidence might have implicitly rested on those same misjudgments. The state court, we have little doubt, can evaluate such matters better than we. It must do so as the first step in assessing Madison’s competency—and ensuring that if he is to be executed, he understands why.[9] ”

    Dissenting opinion

    Justice Samuel Alito filed a dissenting opinion, in which Justices Clarence Thomas and Neil Gorsuch joined. Justice Alito wrote,

    “ Petitioner has abandoned the question on which he succeeded in persuading the Court to grant review, and it is highly improper for the Court to grant him relief on a ground not even hinted at in his petition. The writ should be dismissed as improvidently granted, and I therefore respectfully dissent.[9] ”

    Text of the opinion

    • Read the full opinion here.

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 Supreme Court of the United States, Madison v. Alabama, accessed August 15, 2018
    2. ↑ 2.0 2.1 2.2 2.3 2.4 United States Supreme Court, "Madison v. Alabama," Opinion, February 27, 2019
    3. ↑ 3.0 3.1 3.2 3.3 3.4 SCOTUSblog, "Madison v Alabama case file," accessed August 15, 2018
    4. ↑ 4.0 4.1 Alabama 13th Judicial Circuit, Vernon Madison v. State of Alabama, January 16, 2018
    5. ↑ 5.0 5.1 AL.com, "Execution date set for Alabama death row inmate, convicted in 1985 Mobile police officer's slaying," November 22, 2017
    6. ↑ The New York Times, "Too Old to Be Executed? Supreme Court Considers an Aging Death Row," March 5, 2018
    7. ↑ Death Penalty Information Center, "U.S. Supreme Court Stays Alabama Execution to Consider Vernon Madison's Competency to Be Executed," accessed August 28, 2018
    8. ↑ Supreme Court of the United States, Madison v. Alabama, argued October 2, 2018
    9. ↑ 9.0 9.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
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