Criminal Law Library Blog
Executive Summary
This article examines whether the Supreme Court’s current standards for determining competence to be executed adequately protect individuals with severe cognitive impairments and mental illnesses. While landmark decisions , Ford v. Wainwright (1986), Panetti v. Quarterman (2007), and Madison v. Alabama (2019) , established that a person must possess a rational understanding of the connection between their crime and punishment, critics argue the framework remains unclear, inconsistently applied, and insufficiently protective.
The case of Ralph Menzies, a Utah death row inmate suffering from vascular dementia, illustrates these concerns. Despite serious cognitive decline and an inability to comprehend his punishment, Utah continues to pursue his execution. The Court’s standard leaves wide discretion to the states, creating procedural disparities, frequent “battles of the experts,” and significant hurdles for inmates, who bear the burden of proving their own incompetence.