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In Panetti v. Quarterman, the United States Supreme Court held that the incompetence standard used by the United States Court of Appeals for the Fifth Circuit was overly restrictive and failed to afford proper Eighth Amendment protection to a prisoner convicted of murder. While Ford v. Wainwright established that a prisoner is competent for execution if he or she knows of his or her impending execution and the reason for it, the Court expanded the competency standard in Panetti by holding that a prisoner's awareness of the rationale for an execution is not the same as a rational understanding of its basis. Hence, a trial court should consider if the gross delusions of a death row inmate preclude the inmate's awareness of his execution.