Panetti v. Quarterman

Facts of the Case

Petitioner Scott Louis Panetti was convicted of capital murder in a Texas state court and sentenced to death despite his well-documented history of mental illness. After the Texas courts denied relief on direct appeal, Panetti filed a federal habeas petition pursuant to

Question

Does the Eighth Amendment permit the execution of an inmate who has a factual awareness of the State’s stated reason for his execution, but who lacks, due to mental illness, a rational understanding of the State’s justification?

CONCLUSION

Unanswered. In an opinion written by Justice Anthony Kennedy for a 5-4 majority, the Court held that the Fifth Circuit’s analysis was too restrictive under Ford v. Wainwright , because it treated Panetti’s mental condition as irrelevant as long as he had in some sense a factual awareness of the state’s rationale. The Court rejected the state’s arguments that the Court did not have jurisdiction and that the state court was entitled to deference under the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA). In doing so, the Court held that a prisoner may sometimes bring a habeas petition claiming mental incompetency even if he did not raise the claim in his first petition and that state courts can be held to have unreasonably applied a legal principle even if the principle was addressed to somewhat different facts than those of the case at hand. The state court had unreasonably applied Ford by failing to give Panetti a fair hearing to fully present his psychiatric evidence. The Court also ruled that the Fifth Circuit rests on a flawed interpretation of Ford , because it failed to consider that Panetti’s delusions may have prevented him from understanding the meaning of his punishment even though he professed to be aware of the facts. The Court did not undertake its own analysis of what kind of rational understanding the Eighth Amendment requires a death row inmate to have, saying, Although we reject the standard followed by the Court of Appeals, we do not attempt to set down a rule governing all competency determinations. The Court expressed the hope that expert psychiatric evidence would shed light on which delusions might distort an inmate’s sense of reality so much as to render him incompetent to be executed.

Case Information

  • Citation: 551 US 930 (2007)
  • Granted: Jan 5, 2007
  • Argued: Apr 18, 2007
  • Decided Jun 28, 2007