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

Summary: In 1985, 34-year-old Vernon Madison shot and killed a police officer in Alabama and was later convicted of capital murder and sentenced to death. However, since his conviction and during his 30 years on death row, Madison suffered from severe vascular dementia as a result of multiple strokes. Consequently, Madison had no memory of committing his crime. The state of Alabama had scheduled his execution date for May 2016, but Madison petitioned the Alabama Circuit Court for a writ of habeas corpus on the basis that the execution violated the Eighth Amendment of the U.S. Constitution due to the fact that “[Madison] could no longer recollect committing the crime from which he had been sentenced to die.” After an evaluation, the Alabama Circuit Court found that Madison was competent to be executed; however, Madison then appealed the decision to the U.S. Supreme Court, and a writ of certiorari was granted in 2018.

In February 2019, the U.S. Supreme Court ruled that while memory loss alone does not necessarily bar execution, the Eighth Amendment prohibits a person from being executed if they do not “rationally understand” why they are being executed, which in Madison’s case, he did not; thus, the U.S. Supreme Court granted Madison a stay of execution in a 5-3 ruling.

Key Words: Eighth Amendment, death penalty, stay of execution, SCOTUS, vascular dementia, Alabama