Ford v. Wainwright

477 U.S. 399 (1986)

Facts and Procedural History:

In 1974 Ford was convicted of murder in a Florida state court and sentenced to death. In early 1982 he began to show gradual changes in behavior, indicating mental disorder. Counsel for Ford invoked the procedures of Florida law governing the determination of a condemned prisoner's competency. According to the procedures, the Governor of Florida appointed a panel of three psychiatrists to evaluate whether Ford had "the mental capacity to understand the nature of the death penalty and the reasons why it was imposed upon him." The psychiatrists disagreed on the exact diagnosis but agreed on the fact of Ford’s sanity. The Governor without explanation or statement signed a death warrant for the execution.

Ford’s attorneys unsuccessfully sought a hearing in state court for determination of his competency and then filed a habeas corpus petition. Federal district and appellate courts denied relief.

Issue Presented to the Court:

The Supreme Court granted certiorari to determine (1) whether the Eighth Amendment prohibits the execution of the insane and, if so, (2) whether the District Court should have held a hearing on petitioner's claim.

Outcome of the Case:

With respect to the first issue the Court held that the Eighth Amendment prohibits the state from inflicting the penalty of death upon a prisoner who is insane and not aware of his impending execution and of the reasons for it. The rationale for this conclusion, found in English common law, is that such an execution has questionable retributive and no deterrence value, and, thus, simply offends humanity.

As to the second issue, the Court concluded that Florida's procedures for determining sanity of a death row prisoner were not "adequate to afford a full and fair hearing" on the critical issue. First, Ford was denied a fact-finding procedure and evidentiary hearing on the question of his competence to be executed and thus precluded from presenting material relevant to his sanity. Second, he was denied an opportunity to challenge or impeach the state-appointed psychiatrists' opinions, thus creating a significant possibility that the ultimate decision made in reliance on those experts was distorted. And finally, the Court held that any procedure, which places the ultimate decision wholly within the Executive Branch, is necessarily inadequate.

Accordingly, Ford was entitled to de novo evidentiary hearing in the federal district court on the question of his competence to be executed.