Panetti v. Quarterman

The Appellant, Panetti, was convicted of capital murder in a Texas state court and sentenced to death. After the execution date was set, Panetti brought proceedings claiming that he was incompetent to be executed. The federal district court stayed Panetti’s execution in order to allow the state courts to adjudicate Panetti’s claim of mental incompetence. As a result, the state trial court appointed two mental health experts to evaluate Panetti who concluded that Panetti was competent to be executed. Based on this evaluation, the judge found Panetti competent and closed the case.

Panetti then brought proceedings alleging that the trial court’s procedures did not comply with the standard established in Ford v. Wainwright, 477 U.S. 399 (1986), which held that, under the Eighth Amendment, a prisoner who had made the requisite preliminary showing that his current mental state would bar his execution was entitled to an adjudication to determine his condition.

The federal District Court held that state courts had not complied with the procedural requirements of Ford, but it denied habeas corpus relief holding that it was enough that Panetti knew simply that he was about to be executed and the reasons for it. The Court of Appeals for the Fifth Circuit affirmed the decision and this appeal followed.

The Court held that the State had failed to provide Panetti with the procedures to which he was entitled under the Eighth and Fourteenth Amendments of the Constitution. Reaffirming Ford, it held that once a prisoner seeking a stay of execution had made a substantial threshold showing of insanity (which Panetti had) the Eighth and Fourteenth Amendments entitled him to a fair hearing, including an opportunity to submit expert psychiatric evidence that may differ from the State’s own psychiatric examination. It found that the state court reached its competency determination without holding a hearing or providing Panetti with an adequate opportunity to submit psychiatric evidence as a counterweight to the report filed by court-appointed experts. The Court held that the procedures afforded to Panetti could not be “reconciled with any reasonable application of the controlling standard in Ford.”

The Court made no holding as to the precise constitutional standard governing competency determinations for the purposes of executing mentally ill criminals. It did however affirm Ford, stating that the Constitution placed “a substantive restriction on the State’s power to take the life of an insane prisoner” because such executions served “no retributive purpose.” It added that the objectives of deterrence and retribution were questionably met when “the prisoner’s only awareness of the link between the crime and the punishment [was] so distorted by mental illness that his awareness of the crime and punishment [had] little or no relation to the understanding shared by the community as a whole.”

“Justice Powell's opinion states the relevant standard as follows. Once a prisoner seeking a stay of execution has made ‘a substantial threshold showing of insanity,’ the protection afforded by procedural due process includes a ‘fair hearing’ in accord with fundamental fairness. Ford, 477 U.S., at 426, 424, 106 S.Ct. 2595 (opinion concurring in part and concurring in judgment) (internal quotation marks omitted). This protection means a prisoner must be accorded an ‘opportunity to be heard,’id.,at 424, 106 S.Ct. 2595(internal quotation marks omitted), though ‘a constitutionally acceptable procedure may be far less formal than a trial,’ id., at 427, 106 S.Ct. 2595. As an example of why the state procedures on review in Ford were deficient, Justice Powell explained, the determination of sanity ‘appear[ed] to have been made solelyon the basis of the examinations performed by state-appointed psychiatrists.’ Id., at 424, 106 S.Ct. 2595. ‘Such a procedure invites arbitrariness and error by preventing the affected parties from offering contrary medical evidence or even from explaining the inadequacies of the State's examinations.’ Ibid.” 128 S.Ct., p. 2856.”

“The flaws of the Court of Appeals' test are pronounced in petitioner's case. Circuit precedent required the District Court to disregard evidence of psychological dysfunction that, in the words of the judge, may have resulted in petitioner's ‘fundamental failure to appreciate the connection between the petitioner's crime and his execution.’ 401 F.Supp.2d, at 712. To refuse to consider evidence of this nature is to mistake Ford's holding and its logic. Gross delusions stemming from a severe mental disorder may put an awareness of a link between a crime and its punishment in a context so far removed from reality that the punishment can serve no proper purpose. It is therefore error to derive from Ford, and the substantive standard for incompetency its opinions broadly identify, a strict test for competency that treats delusional beliefs as irrelevant once the prisoner is aware the State has identified the link between his crime and the punishment to be inflicted.” 128 S.Ct., p. 2862.