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Constitutional Law Keyed to Choper
Madison v. Alabama
Citation:
139 S. Ct. 718 (2019)Facts
Vernon Madison killed a police officer during a domestic dispute in 1985 and was sentenced to death. After decades on death row, Madison suffered several strokes in 2015 and 2016, resulting in vascular dementia, cognitive impairment, and memory loss. He claimed he could no longer remember committing the murder for which he was sentenced to die. Madison petitioned the state court to stay his execution based on mental incompetence. Two psychologists evaluated Madison: his expert, Dr. Goff, found that while Madison understood execution in the abstract, his dementia prevented him from comprehending why Alabama sought to execute him specifically; the state’s expert, Dr. Kirkland, found Madison understood his legal situation but focused on the absence of psychosis or delusions. The state court found Madison competent to be executed, emphasizing that he was not delusional. After federal habeas proceedings and a Supreme Court reversal, Madison returned to state court, which again found him competent for execution.
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