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Panetti v. Quarterman
United States Supreme Court
551 U.S. 930 (2007)
Scott Panetti (defendant) was sentenced to death after being convicted of a double murder. During his trial, Panetti was subject to a court-ordered psychiatric evaluation. The evaluation indicated Panetti suffered from fragmented personality, delusions, and hallucinations. At one point, he had been prescribed medication for extreme psychosis, which could be tolerated only by someone actually suffering from psychosis according to one expert witness. Panetti’s standby counsel at trial described Panetti’s behavior as indicative of mental incompetence. After exhausting various state remedies, Panetti brought a petition for federal habeas corpus relief (his second federal habeas petition), seeking a finding that he was not mentally competent to be executed. The federal district court stayed Panetti’s execution to give the state court time to consider Panetti’s renewed motion to determine competency to be executed. The state court eventually appointed two mental-health experts to evaluate Panetti. The experts determined Panetti was competent to be executed. Panetti filed an objection to the experts’ report, but the state court found Panetti competent based on the two court-appointed experts and closed the case without addressing Panetti’s offer of evidence and arguments in various motions he had filed. Panetti returned to federal court on his federal habeas claim. The district court conducted an evidentiary hearing, which included testimony from multiple experts offered by both Panetti and the state indicating Panetti suffered from delusions and did not truly understand the reason he was to be executed. The district court held that the state proceedings had been constitutionally inadequate but denied relief because the court found Panetti competent, applying a strict test for competency that merely inquired as to whether the prisoner was aware he would be executed and why. The appellate court affirmed. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Kennedy, J.)
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