July 16, 2014
Link to Supreme Court of Missouri Opinion
On
July 16, 2014, after 20 years and at least three stays of execution, a sharply
divided Missouri Supreme Court issued a brief opinion rejecting John C.
Middleton’s final attempt to evade the death penalty.[i] Following two initially successful but
eventually fruitless attempts to bypass the state’s Supreme Court by imploring
the federal district court for the Eastern District of Missouri to stay his
execution,[ii] on
July 16 Middleton filed a writ of habeas corpus asserting that under the Eight
Amendment he lacked the mental competence which the constitution requires for
an inmate to be executed.[iii] Relying on the United States Supreme Court’s Panetti v. Quarterman[iv]
and Ford v. Wainwright[v] decisions, the majority held that
Middleton had fallen well short of establishing that he was suffering from the
sort of gross psychotic delusions that might have presented a constitutional
bar to his execution.[vi] The dissent, on the other hand, written by
Justice Draper, and concurred in by Justices Stith and Teitelmann, strongly
criticized what it perceived to be the gross violation of Middleton’s right to
due process.[vii] Justice Draper’s dissenting opinion insisted
that the same psychiatric report viewed as inadequate by the majority was a
sufficient predicate for establishing a threshold showing of incompetence. Further, the dissent argued that Middleton
had raised substantial unanswered concerns regarding the constitutionality of
RSMo § 552.060, which governs the procedure for determining whether a condemned
prisoner is competent to be executed.[viii]
