Brief Fact Summary.
Defendant was convicted of murder and sentenced to death. Defendant’s attorneys sought a writ of habeas corpus, arguing that Defendant was not competent to understand the nature of the death penalty and the reasons why it was imposed on him.
Synopsis of Rule of Law.
The Eight Amendment prohibits the execution of an insane person.
Alvin Ford (Defendant) was convicted of murder and sentenced to death. While in prison, Defendant’s behavior began to change, and he started experiencing numerous suicidal delusions related to the Ku Klux Klan. Defendant also believed that a large group of his friends and family was being held hostage inside the prison. After examination, a psychiatrist concluded that Defendant suffered from severe paranoid schizophrenia. Shortly afterward, a second doctor met with Defendant and concluded that Defendant did not understand why he was being executed or recognize the relationship between his death sentence and the homicide of which he had been convicted. Following the procedures set forth under Florida law for determination of competency of a condemned inmate in Fla. Stat. § 922.07 (1985), the governor of Florida empanelled three psychiatrists to evaluate whether Defendant had the mental capacity to understand the nature of the death penalty and the reasons why it was imposed on him. After interviewing Defendant at a single meeting, all three psychiatrists produced different diagnoses, but all agreed that Defendant understood the nature and effects of the death penalty. Pursuant to the statute, the governor made the final decision, based upon the psychiatrists’ conclusions, and signed a death warrant for Defendant’s execution. Defendant’s attorneys subsequently brought an action in federal court seeking a writ of habeas corpus.
Whether the Eighth Amendment prohibits the execution of an insane prisoner.
Yes. The case is remanded. The Eight Amendment prohibits the execution of an insane person.
Creating a constitutional right to a judicial determination of sanity before carrying out a death sentence unnecessarily complicates this area of law.
The Eighth Amendment prohibits execution of the insane only if the person does not understand the punishment or the reason for it. Defendant is one such person. While Florida’s procedures are constitutionally defective, a full-scale, adversarial competency hearing should not be required.
There is no substantive right arising from the Eighth Amendment not to be executed while insane. However, the judgment should be vacated and remanded. The state has created a liberty interest in avoiding execution while incompetent. Florida has not provided the minimal procedural due process protections required to protect that liberty interest.
The Eighth Amendment of the United States Constitution prohibits “cruel and unusual punishment,” which includes execution of a prisoner who is incompetent. Whether a particular punishment comports with the amendment is evaluated by considering both traditional and contemporary societal values and justifications. At common law, the practice of executing a prisoner who lost his sanity was extensively condemned and considered cruel and inhuman. A number of potential reasons supported this widespread condemnation of the procedure, including that execution of an insane person is simply an affront to humanity and that it does not provide an example to others and has therefore no deterrence value, along with various religious explanations. Today, many of these justifications are still compelling. The retributive purpose of the death penalty is not served when a person does not understand why he is being put to death, and the natural unease and repugnance toward the practice is felt throughout the country. Because this restriction arises from the Constitution, condemned prisoners have a right to fair and independent fact-finding procedures to determine present insanity. Here, the Florida procedures under § 922.07 are inadequate and flawed, because they do not comport with due process requirements. The procedures do not allow the prisoner to submit his own material to be considered in the final decision and thus do not provide an opportunity to be heard. There is also no chance to confront the state-appointed psychiatrists’ or challenge their opinions, which is an important element of a truth-seeking process. Lastly, the insufficiently neutral executive branch has complete power over the ultimate decision. Though this Court will not set forth an exhaustive list of necessary procedures, each state must develop appropriate ways to enforce the constitutional restriction upon executions of potentially mentally ill inmates.