8TH Amendment – Suspension of Death Sentence

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United States Supreme Court

Case Name: Jefferson Dunn v. Vernon Madison

Case No.: 17-193

Focus: 8^TH Amendment  – Suspension of Death Sentence

More than 30 years ago, Vernon Madison crept up behind police officer Julius Schulte and shot him twice in the head at close range. An Alabama jury found Madison guilty of capital murder. The trial court sentenced him to death. See Ex parte Madison, 718 So. 2d 104, 105–106 (1998).The state court did not unreasonably apply Panetti and Ford when it determined that Madison is 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. In 2016, as Madison’s execution neared, he petitioned the trial court for a suspension of his death sentence. He argued that, due to several recent strokes, he has become incompetent to be executed.

The trial court denied Madison’s petition. It held that, under this Court’s decisions in Ford v. Wainwright, 477 U. S. 399 (1986), and Panetti v. Quarterman, 551 U. S. 930 (2007), Madison was entitled to relief if he could show that he “suffers from a mental illness which deprives [him] of the mental capacity to rationally understand that he is being executed as a punishment for a crime.” App. to Pet. for Cert. 74a. The court concluded that Madison had failed to make that showing. Madison then filed a petition for a writ of habeas corpus in Federal District Court. The District Court denied Madison’s petition after concluding that the state court “correctly applied Ford and Panetti” and did not make an “unreasonable determination of the facts in light of the evidence.” App. to Pet. for Cert. 67a. We disagree. In Panetti, this Court addressed the question whether the Eighth Amendment forbids the execution of a prisoner who lacks “the mental capacity to understand that [he] is being executed as a punishment for a crime.” 551 U. S., at 954 (internal quotation marks omitted). The state court did not unreasonably apply Panetti and Ford when it determined that Madison is 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.

Nor was the state court’s decision founded on an unreasonable assessment of the evidence before it. Testimony from each of the psychologists who examined Madison supported the court’s finding that Madison understands both that he was tried and imprisoned for murder and that Alabama will put him to death as punishment for that crime. In short, the state court’s determinations of law and fact were not “so lacking in justification” as to give rise to error “beyond any possibility for fairminded disagreement.” Richter, supra, at 103. Under that deferential standard, Madison’s claim to federal habeas relief must fail. We express no view on the merits of the underlying question outside of the AEDPA context. The petition for a writ of certiorari and respondent’s motion to proceed in forma pauperis are granted, and the judgment of the Court of Appeals is reversed.

Petition Granted. Reversed and remanded.

Dissenting:

Concurring: Ginsburg, Breyer, Sotomayor

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Attorney Derek A. Hawkins is the managing partner at Hawkins Law Offices LLC, where he heads up the firm’s startup law practice. He specializes in business formation, corporate governance, intellectual property protection, private equity and venture capital funding and mergers & acquisitions. Check out the website at www.hawkins-lawoffices.com or contact them at 262-737-8825.