Charles Laverne Singleton was sitting on death row for stabbing a woman to death in 1979. On March 9th of this year, he came before the Supreme Court of Arkansas on a petition requesting that his execution, scheduled for March 11th, be stayed. The issue before the court was "whether the State can mandatorily medicate him with antipsychotic drugs in order to keep him from being a danger to himself and others when a collateral effect of that medication is to render him competent to understand the nature and reason for his execution."
Before deciding the case, the court discussed the U.S. Supreme Court case of Washington v. Harper, 494 U.S. 210 (1990), which prohibits involuntary medication of a prisoner which will make him fit for execution without a determination that such medication is for his safety as well as the safety of others. The court in the present case noted that a medication review panel had found legitimate reason for medicating Singleton involuntarily and that this determination, coupled with a set execution date, rendered the case ripe for determination.
Holding: The court granted the stay in order to let the lower court make the determination. The court noted while ordinarily it would only hear this issue on appeal, there was hardly time for a lower court substantive determination and a meaningful appeal when Singleton was scheduled to be executed in two days. "It would be an anomaly in our law with the direst of consequences if a bona fide constitutional claim made ripe by the medication review panel's action ... and by the fixing of an execution date could not be decided prior to execution," the court stated.
| Micheal R. Arambula, M.D. Clinical Assistant Professor and Director University of Texas Health Science Ctr |
Dr. Arambula comments: In my own experience in death penalty litigation, I occasionally come across a capital defendant with serious mental illness; these individuals usually traverse our legal system without medication interventions. The last time I went to death row to evaluate such an inmate, I couldn't help but notice that the staff treated him as though he was any other death row inmate. What I observed was akin to someone talking to an individual with a severe facial deformity. Perhaps I read into the guards' interactions with the inmate in finding that they were trying to ignore the obvious. Nonetheless, as a trained expert in human behavior, I could not overlook their clumsiness.
I have come to realize that any contribution I may have to a case like this is small in comparison to the multitude of penal, legal, political and community issues that affect this inmate's situation. As a consequence, it has been important for me not to overestimate the influence that I may ultimately have on the outcome of an inmate's case and/or appeal. While the law requires that a death row inmate be competent to undergo execution, I humbly know that a psychiatric opinion of incompetence is in no way, shape or form, a trump card for that individual's future existence.
Although worlds apart in ambiance, I see some similarity between mentally ill capital convicts and mentally ill homeless individuals on the streets of my community. Driving by a homeless person who looks mentally ill, I know they would have a better quality of life receiving appropriate psychiatric treatment and follow-up. Although I can do nothing in my capacity as a psychiatric physician, it nevertheless tugs at me from a personal level that I have to look the other way. Perhaps the guards on death row struggle with these same issue; it can even explain how mentally ill death row inmates can be treated like the rest of the inmate population. No amount of legal expertise/words can legitimately lay to rest the inherent tension that Singleton raises.