Vernon Madison v. Commissioner, Alabama Department of Corrections

MARTIN, Circuit Judge:

Thirty years ago, the Supreme Court held that the Eighth Amendment prohibits the execution of a person who is incompetent.1 Ford v. Wainwright, 477 U.S. 399, 409-10, 106 S.Ct. 2595, 2602, 91 L.Ed.2d 335 (1986). The Court has since clarified that a person cannot be executed if he lacks a “rational understanding” of the reason for his execution. Panetti v. Quarterman, 551 U.S. 930, 954-60, 127 S.Ct. 2842, 2859-62, 168 L.Ed.2d 662 (2007). This standard requires the prisoner to be able to rationally understand the connection between the crime he committed and the punishment…