In Madison v. Alabama (2019), the Supreme Court ruled that the Eighth Amendment to the Constitution bars the execution of a prisoner whose dementia prevents him from recalling his crime and understanding why the state seeks to execute him.
Vernon Madison killed a police officer in 1985 during a domestic dispute. An Alabama court found him guilty and sentenced him to death. In the ensuing decades, Madison’s mental condition deteriorated. After a series of strokes, Madison was diagnosed with vascular dementia, characterized by disorientation, confusion, cognitive impairment, and memory loss. In 2016, Madison petitioned the trial court for a stay of execution on grounds that he had become mentally incompetent. That court ruled that Madison was competent for execution because he had not demonstrated that he was delusional or psychotic.
On appeal, Madison argued that the Eight Amendment should bar his execution because he did not remember killing the officer and because dementia prevents him from understanding why Alabama seeks to execute him.
The Court began by rejecting Madison’s argument that his failing memory should bar his execution. The Court stated that previous precedent, Panetti v. Quarterman (2007), barred executions of prisoners who suffered from psychotic delusions. The Court noted that the reason for this requirement is that an execution lacks a “retributive purpose” when a mentally ill prisoner does not understand why he will be executed. Panetti focused on understanding, not memory of the crime. The Court used an analogy to highlight that the memory of an event or conduct is less significant, for Eighth Amendment purposes, than the consequences of the conduct: “Do you recall your first day of school? Probably not. But if your mother told you years later that you were sent home for hitting a classmate, you would have no trouble grasping the story. And similarly, if you somehow blacked out a crime you committed, but later learned what you had done, you could well appreciate the State’s desire to impose a penalty.”
Turning to the next issue, the Court pointed out that Madison did not contend that he suffered from psychotic delusions. But the Court declared that the significance of Panetti lies not in the specific type of mental illness, but the effect of the illness. “The Panetti standard concerns . . . not the diagnosis of such illness, but a consequence—to wit, the prisoner’s inability to rationally understand his punishment.” If the prisoner cannot understand why the state seeks execution, the Court held, then the state cannot lawfully execute the prisoner.
The Court concluded that whether Madison truly understood why Alabama sought to execute him was unclear from the record. The Court therefore stayed the execution and returned the case to the trial court for proceedings to determine whether Madison understood the purpose of his sentence.