Kaleb Byars

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In 1985, Vernon Madison killed a police officer in Alabama. At trial, an Alabama jury convicted Madison of capital murder, and the trial court sentenced him to death. While awaiting his execution, Madison suffered strokes and was diagnosed with several mental disorders, including vascular dementia. Madison averred these disorders, particularly vascular dementia, rendered him unable to remember committing his crime. Accordingly, Madison petitioned to stay his execution, arguing his disorders rendered him mentally incompetent. Particularly, Madison argued the inability to remember committing the murder prevented him from understanding his conviction. ...

Part I of this Article has introduced the facts of Madison v. Alabama and its central holding. Next, Part II will address other Supreme Court jurisprudence on execution of mentally incompetent prisoners. Part III further discusses the Court’s holding in Madison v. Alabama. Part IV provides an analysis of the Court’s holding, specifically noting implications the Court failed to consider. Further, Part IV discusses other issues related to executing mentally ill prisoners that may arise following Madison v. Alabama. Part V briefly concludes.