Madison v. Alabama

Madison v. Alabama, 586 U.S. ___ (2019), was a United States Supreme Court case regarding the Eighth Amendment to the United States Constitution, barring cruel and unusual punishment. The case deals with whether the Eighth Amendment prohibits executing a person for a crime they do not remember.

Vernon Madison (August 22, 1950 – February 22, 2020) shot police officer Julius Schulte twice in the back of the head in Mobile, Alabama in April 1985. Schulte was mediating a domestic disturbance between Madison and his ex-girlfriend; Madison also shot and injured her. Madison was an inmate at Holman Correctional Facility from September 1985 up until his death on February 22, 2020.

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 introduced evidence improperly. In the third trial, the jury decided on a sentence of life in prison, but the judge Ferrill McRae overruled them and gave Madison a sentence of death in 1994.

The execution was scheduled to occur in May 2016; the 11th Circuit Court of Appeals granted a stay on the day of the execution, which the Supreme Court upheld 5-3 (at the time, one seat on the nine-member court was empty owing to Justice Antonin Scalia's death 3 months prior).

In Dunn v. Madison, in November 2017, the Supreme Court unanimously overturned a 2-1 decision by the 11th Circuit, which had stopped the execution on the basis that Madison "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". The Supreme Court did not rule on the merits of the case, but ruled that the Circuit Court overstepped its authority 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 execution was scheduled for January 2018; the Supreme Court granted a stay 30 minutes before Madison was scheduled to be executed, with Clarence Thomas, Samuel Alito, and Neil Gorsuch dissenting.

Madison had severe strokes in 2015 and 2016, resulting in vascular dementia and leaving him unable to remember killing officer Schulte. Prior to his death, he was blind and had suffered a severe mental decline; he only remembered the alphabet up to the letter G and had slurred speech. The strokes caused physical damage as well, leaving him incontinent and unable to walk without a walker. However, according to the psychologist appointed by Alabama courts seeking his execution, he understood that he would be executed and the reason for that.

In Ford v. Wainwright, the Supreme Court held in 1986 that executing the insane is not allowed due to the Eighth 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.