Mental ability to face execution
Dunn v. Madison
In brief
The Supreme Court overturned the appeals court’s ruling in Madison’s case, but did not answer the broader question about executing someone who cannot remember the crime.
- Where it stands
- Decided
Decided 9-0 · November 6, 2017 · Per curiam
- What it’s about
- Vernon Madison, an Alabama death-row prisoner who had suffered strokes and could not remember the crime, argued that he was not mentally able to be executed.
- Who it affects
- The ruling wiped out the appeals court’s judgment in Madison’s case; it left unanswered whether a state may execute someone who cannot remember the crime.
Summary: written with AI from the case record.

What it's about
The Supreme Court overturned the appeals court’s ruling, finding Alabama’s decision that Madison was mentally able to be executed was not unreasonable enough for a federal court to grant relief; it did not decide whether a state may execute someone who cannot remember the crime.
At a hearing, both psychologists said Madison understood he faced execution for murder. The psychologist hired by Madison’s lawyer said strokes had left him unable to remember the crime; the court-appointed psychologist found he understood his case and sentence.
An Alabama trial court refused to pause Madison’s death sentence after finding he understood he was to be executed as punishment for murder.
Question presented
Was the state court objectively unreasonable in concluding that Madison was competent to be executed?
What the Court decided
Holding
The petition for a writ of certiorari and respondent’s motion to proceed in forma pauperis are granted, and the judgment of the Court of Appeals is reversed.
- Result
- Reversed
The vote
- Joined the judgment
- Concurred in a separate opinion
- Wrote an opinion
- Concurring · 3agreed with the result, wrote separately
- Breyerwrote separately
- Ginsburgwrote separately
- Sotomayorwrote separately
What's next
The Supreme Court has finished this docket action; no further step is specified.
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: question_presented, extraction_metadata
Case data updated: summary, question_presented, generation_metadata
Show 2 moreShow fewer
Opinion added: Dunn
Opinion added: Opinion
More questions
- What reason did Justice Ginsburg give for leaving the memory question open?
- She said a federal law limiting review of state prisoners’ claims kept the Court from deciding that broader question in this case.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.