## Facts

- Vernon Madison was convicted for the 1985 murder of a Mobile police officer responding to a domestic disturbance; Madison also shot and injured his ex-girlfriend.
- Madison was tried three times; the first two convictions were set aside for jury-selection and evidentiary errors.
- At the third trial, the jury recommended life without parole, but the judge imposed a death sentence.
- On death row, Madison suffered multiple strokes and was diagnosed with vascular dementia causing cognitive impairment, disorientation, and memory loss; he became legally blind and physically debilitated.
- Madison asserted he could not remember the crime or the events leading to his death sentence.
- Madison sought a stay in state court, arguing he was incompetent to be executed under the Eighth Amendment.
- Alabama argued Madison could still rationally understand why the State planned to execute him even if he lacked memory of the offense.
- State courts found Madison competent; the Supreme Court granted review on direct appeal from the state competency determination.

## Issues

1. Does the Eighth Amendment categorically prohibit executing a prisoner who cannot remember committing the capital offense?
2. Does the Eighth Amendment’s bar on executing the incompetent apply when the prisoner’s impairment is dementia or another non-psychotic disorder, if it prevents a rational understanding of the State’s reason for execution?

## Decision

- The Court held the Eighth Amendment does not categorically bar execution solely because a prisoner cannot remember committing the crime.
- The Court held the Eighth Amendment’s competency protection is not limited to psychotic delusions; dementia or other disorders can render a prisoner incompetent if they prevent rational understanding of the reason for execution.
- The Court vacated the state court judgment and remanded for reconsideration under the correct standard.
- Justice Alito dissented, joined by Justices Thomas and Gorsuch; Justice Kavanaugh did not participate.

## Legal Principles

- The Eighth Amendment forbids executing a prisoner whose mental condition prevents a rational understanding of the State’s rationale for execution.
- The controlling inquiry is rational understanding of why the State seeks execution, not whether the prisoner can recall the crime.
- Competency is diagnosis-neutral: psychosis, dementia, or other cognitive disorders may qualify if their functional effects defeat rational understanding.
- A state court errs if it treats the absence of psychotic delusions as dispositive or treats dementia as irrelevant to the competency analysis.

## Conclusion

The Court clarified that memory loss alone does not establish incompetency to be executed, but the Eighth Amendment bars execution when dementia or another mental disorder deprives the prisoner of a rational understanding of why the State is carrying out the death sentence; the case was remanded for application of that standard.


Madison v. Alabama, 139 S. Ct. 718 (2019)