Globally, some jurisdictions are alleged to be incompetent due to several reasons. For instance, it is unconstitutional for a court of law to imprison an insane person for a crime they committed since their mental capacities are abnormal. In the same context, Madison had been on death row for over 30 years in Alabama, and over this period, he has experienced several strokes. These strokes damaged his brain such that he could not remember the crimes he committed. Therefore, in 2016 before his execution date, he sought a habeas corpus relief in Federal Court, and for the Eleventh Circuit, the US Court of Appeal ruled that he was incompetent for execution. However, his grant was reversed in November 2017 after his petition was reviewed under AEDPA Act of 1996. A year later, before his execution in January 2018, he petitioned again for relief, citing that the expert who the Court relied on testimony had been suspended from the practice of psychology. However, his claim was denied, and the Court proved his competency for execution.
Consequently, this case brought two questions before the Court concerning the Eighth amendment. According to Oyez, the first question was if a state could be prohibited from executing a prisoner, whose mental disability has erased his memory of committing a capital offense, by the Eighth Amendment and the Court’s jurisprudence. The second question was if a state could be barred from executing a prisoner, who has suffered from cognitive dysfunction such that the prisoner cannot remember his crime or circumstances of his execution by the prohibition of the Eighth Amendment from unusual and cruel punishment.
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In conclusion, the Court ruled that the Eighth Amendment does not prohibit a state from executing a prisoner because he does not remember committing a crime; however, it prohibits the execution of a prisoner who cannot rationally understand the reasons for his execution. Therefore, the Eighth Amendment was not applicable since Madison had not lost his sanity after sentencing. In the lower Court, Madison accepted that his queries were not enforceable under Panetti since it applied to prisoners who have psychosis and not dementia. However, a conflict on dissenting opinion prevailed among Justices on how the case landed on the second question. As a result, Justice Brett Kavanaugh dropped from the consideration and decision of the case.
