Ford v. Wainwright

Ford v. Wainwright

Argued April 22, 1986
Decided June 26, 1986
Full case name Ford v. Wainwright
Docket nos. 85-5542
Citations

477 U.S. 399 (more)

106 S. Ct. 2595; 91 L. Ed. 2d 335; 1986 U.S. LEXIS 64; 54 U.S.L.W. 4799
Argument Oral argument
Prior history Certiorari to the U.S. Court of Appeals for the Eleventh Circuit
Subsequent history Post-conviction relief denied at, Writ of habeas corpus denied Ford v. State, 522 So. 2d 345 (Fla., 1988)
Holding
The Eighth Amendment prohibits the execution of the insane.
Court membership
Chief Justice
Warren E. Burger
Case opinions
Majority Marshall, joined by Brennan, Blackmun, Powell, Stevens
Concur/dissent O'Connor, joined by White
Dissent Rehnquist, joined by Burger
Laws applied
U.S. Const. amend. VIII

Ford v. Wainwright, 477 U.S. 399 (1986), was a U.S. Supreme Court case that upheld the common law rule that the insane cannot be executed; therefore the petitioner is entitled to a competency evaluation and to an evidentiary hearing in court on the question of their competency to be executed.[1]

Circumstances

Alvin Bernard Ford was convicted of murder in 1974 and sentenced to death in the state of Florida. In 1982, while on death row, Ford's mental health diminished to a point resembling paranoid schizophrenia: Ford began referring to himself as Pope John Paul III, and reported such accomplishments as thwarting a vast Ku Klux Klan conspiracy to bury dead prisoners inside the prison walls; foiling an attempt by prison guards to torture his female relatives inside the prison; and personally appointing nine new justices to the Florida Supreme Court. Ford also claimed he was "free to go whenever [he] wanted", because Ford theorized that anyone who executed him would in turn be executed. A panel of three psychiatrists was eventually called to examine Ford's behavior, and concluded that while Ford suffered from psychosis and various mental disorders, that Ford was still capable of understanding the nature of the death penalty and the effect that such a penalty would have on him. The governor of Florida, Bob Graham, acted without further comment on the panel's findings, but in accord with a Florida Statute, and signed a death warrant for Ford in 1984. Ford sued the Secretary of the Florida Department of Corrections, Louie L. Wainwright.[1]

Opinion

The Court, in an opinion by Justice Marshall, reviewed the evolving standards of the Eighth Amendment to be those consistent with "the progress of a maturing society", and one not tolerable of acts traditionally branded as "savage and inhumane", as the execution of the mentally insane was considered in early English and American common law reasoned that executing the insane did not serve any penological goals and that Florida’s procedures for determining competency were inadequate. Thus, the Court made a preliminary finding that the Eighth Amendment bars states from inflicting capital punishment upon insane persons.[1]

The Court then further addressed the procedural issues present in making a determination of insanity for Eighth Amendment concerns. The court found that such a determination could not be left solely to the executive branch, as was done via the Florida Statute allowing then Governor Graham to sign Ford's death warrant solely on recommendation by an appointed committee of psychiatrists. Rather, the Court held, that a proper judicial hearing, in which full procedural rights would be afforded, including the right to counsel and to cross-examine witnesses, was necessary for such a finding.[1]

In their dissents, Justices O'Connor and White claimed that execution of the insane was not per se unconstitutional. The Justices further commented, however, that states had a right to create certain protected liberties in state statutes, of which a prohibition on the execution of the insane was a liberty which could be validly created. Once validly created by a state, that liberty interested required the minimum due process protections afforded to other constitutionally protected liberties, in which sole action by the executive branch, as in this case, would still fail to provide.[1]

Justice Rehnquist, in dissent, stated a belief that in common-law tradition, it was actually the executive branch who was sole arbiter of decisions involving the sanity of prisoners sentenced to death. In this respect, Justice Rehnquist felt that the majority had formed its opinion at the "expense of 'our common law heritage'".[1]

The inmate was transferred to Florida State Hospital for treatment after he was reevaluated and found to be incompetent to be executed.[2][3]

Post-Decision

In 1989, a federal district judge ruled that Ford was in fact sane. Defense lawyers appealed that ruling, and the appeal was pending when Ford died on February 6, 1991 of natural causes at age 37.[4]

See also

Footnotes

  1. 1 2 3 4 5 6 Text of Ford v. Wainwright, 477 U.S. 399 (1986) is available from:  Findlaw  Justia  LII 
  2. ↑ Executing the Mentally Ill: The Criminal Justice System and the Case of Alvin Ford. Sage. Retrieved 2007-10-03.
  3. ↑ "Executing the Mentally Ill". Sage. April 22, 1986. Retrieved 2007-10-03.
  4. ↑ "Alvin Ford, 37, Dies; Stricken on Death Row". 9 March 1991. Archived from the original on 13 January 2013. Retrieved 28 April 2016.
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