U.S. Supreme Court Protects Mentally Ill Convict from Execution
The United States Supreme Court recently decided a case regarding the execution of a mentally ill prisoner set for execution. See the case, Panetti v. Quarterman, Case No. 06-6407 (Decided June 28, 2007). While highly questionable, Scott Louis Panetti was ruled to be competent, not only to stand trial, but to defend himself, at trial. He had later been determined to be delusional.
The Court has previously held that the Eight Amendment's prohibition against cruel and unusual punishment forbids carrying out a sentence of death upon a prisoner who is insane. See Ford v. Wainwright, Case No. 477 U.S. 399 (Decided 1986). In this case, the Court held that prior findings that a defendant was competent do not prevent him from proving he is incompetent to be executed due to his current mental condition.
Panetti had mounted a commando raid on his estranged wife's parent's home, murdering both parents. He then took his wife and daughter hostage for the night, before surrendering to police.
At his 1995 trial, Panetti demanded to represent himself. A court ordered psychiatric evaluation indicated Panetti suffered from a fragmented personality, delusions, and hallucinations. He had been hospitalized numerous times for these disorders. The evaluation revealed that his wife, in 1986, had described an episode where Panetti had become convinced the devil had possessed their home and that, in an effort to cleanse their surroundings, he had buried a number of valuables next to the house and engaged in other rituals. Nonetheless, he was found competent to not only stand trial, but to represent himself.
Panetti's standby counsel described his behaviour during the trial as "bizarre," "scary," and "trance-like." It was obvious to the attorney that Panetti was mentally incompetent. He was convicted of capital murder and sentenced to death. From the start of his trial, Panetti's mental condition only got worse. Panetti appealed both the conviction and his death sentence. His appeal attorney asserted he should never have been allowed to stand trial, much less represent himself.
Following the judge's setting of his date for execution, Panetti finally claimed, for the first time, he was not competent to be executed. The State courts refused to allow Panetti's attorney to present his own psychiatric experts. He was finally allowed to present evidence of his delusional thinking in the Federal District Court. Panetti's psychiatrist testified he suffered from "schizo-affective disorder." While Panetti understood the legal reason he was to be executed, his delusional thinking recast his execution into "part of spiritual warfare. . . between the demons and the forces of the darkness and God and the angels and the forces of light." Panetti thought the State's reason for putting him to death was a sham. The true reason was "to stop him from preaching." However the court found that Panetti's understanding that he committed the murders, that he will be executed, and that the State said he was to be executed for his commission of the crime was sufficient to allow his execution.
The U.S. Supreme Court stopped the execution and decried the failure of the Federal and State courts to protect Panetti. The Court said that once a prisoner seeking a stay of execution shows he may be insane, he is entitled to a fair hearing on the matter, which he was not granted in the State courts. The Court also stated that a prisoner must understand that he is being executed as a punishment for a crime. The Court held, however, that simply knowing the stated reason for his execution does not necessarily amount to "understanding." The Court determined that Panetti's delusions should have taken into account by the lower courts. His mental illness prevented him from actually understanding that he was to be executed, not as part of a battle between good and evil, but as punishment for killing his wife's parents.
The Court explained, however, that some murderers may fail to understand why they're to be executed for reasons other than severe mental illness. As examples, the Court pointed to the prisoner who is so callous as to be unrepentant; so self-centered and devoid of compassion as to lack all sense of guilt; or so adept in transferring blame to others as to be considered to be out of touch with reality. The Court said these states of mind, even if extreme, do not amount to psychiatric disorder, but rather an amoral character.
