Ford v. Wainwright

The Case: U.S. Supreme Court ruling on capital punishment

Date: Decided on June 26, 1986

Significance: This case forced the criminal justice system to examine controversies surrounding mental illness and the death penalty, in particular what types of mental conditions should spare condemned prisoners from execution.

On July 19, 1974, Alvin Bernard Ford was convicted of first-degree murder after shooting a Fort Lauderdale police officer in a robbery attempt. Ford was sentenced to death by electric chair in the Florida court system. During his trial and sentencing, Ford appeared to be mentally competent. After his first year of prison, Ford received only one disciplinary report for his behavior. In 1982, his mental condition gradually began to decline, and he started having delusions. For example, Ford thought that his family was being held hostage at the prison and that the Ku Klux Klan had made him a target of conspiracy. Ford’s communication skills deteriorated; his writing and speaking became incoherent.

Florida law stipulated that if the governor is informed that a death-row inmate may be insane, a commission of psychiatrists must be appointed to examine the person. The examiners must determine whether the person understands the consequences of the death penalty and why it is being imposed. After a thirty-minute interview, two of the three psychiatrists diagnosed Ford as psychotic, yet all three determined that Ford was competent enough to be executed. Relevant testimony of two psychiatrists who had worked with Ford over time, however, was not included in the fact-finding process. They concluded that Ford was severely psychotic and not competent to be executed. No opportunity was given to other knowledgeable experts to dispute the findings of the state-appointed commission. Based on the commission’s results, the governor found Ford to be competent and issued a death warrant for his execution.

Florida’s Eleventh Circuit Court of Appeals stayed the execution to hear the issues. The court decided against Ford. The U.S. Supreme Court agreed to hear Ford’s appeal. In a 5-4 decision, the Supreme Court overturned the decision of the Florida court and ordered that the case be remanded to federal district court for a full hearing. Justice Thurgood Marshall wrote the majority opinion of the Supreme Court. He concluded that the Eighth Amendment prohibits the states from imposing the death penalty on prisoners who are insane. The court found that Florida’s process of evaluating condemned prisoners did not provide adequately for deciding whether Ford was competent to be executed.

Before the federal district court could determine Ford’s competency, Alvin Ford died in prison. His death left issues unresolved, such as how competency is defined, what should be done in cases where the inmate wavers between stages of competency and incompetence, whether medication should be used to restore an inmate’s mental health before execution, and whether mentally retarded inmates are competent for execution.

Bibliography

Conley, R., R. Luckasson, and G. N. Bouthilet. The Criminal Justice System and Mental Retardation: Defendants and Victims. Baltimore: Brookes, 1992.

Fabrega, H. “Culture and Formulation of Homicide: Two Case Studies.” Psychiatry 67 (2004): 178-196.

Lewis, Dorothy Otnow. Guilty by Reason of Insanity: A Psychiatrist Explores the Minds of Killers. New York: Ivy Books, 1999.

Monahan, J. Mental Illness and Violent Crime. Washington, D.C.: U.S. Department of Justice, 1996.

Whitlock, Francis Antony. Criminal Responsibility and Mental Illness. London: Butterworths, 1963.