Ford v. Wainwright Case: Summary

Instructor: Rachael Smith

Rachael has a background in secondary education and has practiced law for eight years.

This lesson examines and summarizes Ford v. Wainwright. This 1986 Supreme Court case evaluated the process we use to determine whether or not a death row inmate is competent enough to face execution.

Background of the Case

In 1974, Alvin Ford was charged with murder, found guilty, and sentenced to death in the state of Florida. Throughout the trial process, Ford's competence, or ability to understand the nature and consequences of the trial and assist in his own defense, was never brought into question. Ford and his attorneys appealed the sentence.

Eight years later, Ford began to show signs that he was not competent any longer. Ford read an article about the Ku Klux Klan and then believed that he was a leader of the group, participating in various Klan events. He also believed that prison officials had kidnapped and tortured his female relatives. Ford accused prison officials of killing people and burying them within the building. Finally, he began to believe that he was Pope John Paul III and that he had taken control of a hostage crisis in the prison by firing prison officials. Ford then only communicated with his attorneys in a code only he knew.

Because of these behaviors, Ford's attorneys asked that a psychiatrist evaluate and treat Ford. After fourteen months of evaluating medical records, listening to recorded conversations between Ford and his attorney, and reading letters written by Ford, the psychiatrist determined that Ford suffered from a severe and persistent mental health condition that impaired his ability to assist in the appeal of his death sentence.

In keeping with Florida law on determining the competency of an inmate, the governor appointed three psychiatrists to assess Ford and see if he understood what the death penalty was and why he received that sentence. All three psychiatrists met Ford for 30 minutes and then filed two- to three-page reports. All three psychiatrists determined that Ford suffered from severe mental health issues, but that he understood enough to be executed. The governor signed a death warrant for Ford.

Review in the Higher Courts

Ford's attorneys asked for a hearing on the matter so that they could question the three psychiatrists and present evidence on Ford's behalf. Their request was denied. They then filed an appeal in Federal District Court asking for a review of the ruling to determine whether there should have been a hearing on Ford's competency. This request was also denied.

Ford appealed the District Court by filing a writ of habeas corpus, a request that the court review the conditions of his imprisonment. A writ of habeas corpus can be used to review a person's imprisonment and the conditions under which he or she is imprisoned. Ford asked that the court determine whether he could be executed given his mental state. Ford's execution was put on hold until the Court of Appeals could review the District Court's denial of a hearing. The Court of Appeals agreed with the District Court and found that Ford was not entitled to a hearing.

Ford petitioned the Supreme Court of the United States (SCOTUS) for a writ of certiorari, a request that SCOTUS determine if the Eighth Amendment allows the State of Florida to execute an incompetent person. Ford v. Wainwright was decided in 1986, with a 5 to 4 vote in favor of Ford.

Rule of Law/Holding of the Case

The Supreme Court issued the following rulings on the two questions presented before it in Ford v. Wainwright. The Eighth Amendment guards against cruel and unusual punishment, and therefore, a prisoner may not be executed who is determined to be insane. Additionally, the Federal District Court should have had a hearing on Ford's competency.

The Eighth Amendment Guards Against Cruel and Unusual Punishment

The Eighth Amendment protects citizens against cruel and unusual punishment; this prevents people from receiving too harsh a sentence or receiving a sentence that is inhumane or barbaric. The idea of cruel and unusual punishment is applicable to the entire scope of death penalty case.

A defendant (person charged with a crime) must be competent during the trial process, so he should also be competent at the stage of his execution. The courts have established that a person who is insane is not able to understand the nature and consequences of their actions. The trial process does not allow the prosecution of someone who is not competent because it goes against the idea of a fair judicial system.

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