Panetti v. Quarterman
Panetti was convicted of capital murder in the state court of Texas and sentenced to death. Shortly before his scheduled execution date, he petitioned the state court for a determination of his competency to be executed. The state habeas court appointed two mental health experts who wrote a report that Panetti knows that he will be executed and that he has the ability to understand the reason why. Based on this report, but without holding a competency hearing, the state habeas court held that Panetti was competent to be executed.
Panetti petitioned for a writ of habeas corpus in federal court. The district court held that the state court’s failure to hold a competency hearing at which Panetti could present evidence was contrary to Ford v. Wainwright, and held a hearing after which it concluded that Panetti was competent. The district court held that it is sufficient that Panetti knows: 1) that he committed two murders; 2) that he will be executed; and 3) that the reason the state has given for that execution is his commission of those murders. On appeal, Panetti argued that the Eighth Amendment forbids the execution of a prisoner who lacks a rational understanding of the State’s reason for the execution. Panetti contends that this understanding is lacking in his case because he believes that, although the State’s purported reason for the execution is his past crimes, the State’s real motivation is to punish him for preaching the Gospel. The Fifth Circuit Court of Appeals affirmed, holding that the standard inFord only requires that a prisoner "perceive[] the connection between his crime and his punishment." Furthermore, the prisoner need only be "aware" of the connection between the crime and the punishment; a “rational understanding” of the punishment is not required to establish that Panetti is competent to be executed.
Questions Presented:
Does the Eighth Amendment permit the execution of a death row inmate who has a factual awareness of the reason for his execution but who, because of severe mental illness, has a delusional belief as to why the state is executing him, and thus does not appreciate that his execution is intended to seek retribution for his capital crime?
The parties are directed to file supplemental briefs addressing the following question: Must petitioners habeas application be dismissed as second or successive pursuant to 28 U.S.C. §2244?
