Texas Court of Criminal Appeals Holds Forcible Medication for Death Row Prisoner Unauthorized
Texas Court of Criminal Appeals Holds Forcible Medication for Death Row Prisoner Unauthorized
On September 11, 2013, the Texas Court of Criminal Appeals held that a trial court lacked authority under the competency-to-be-executed statute, Texas Code of Criminal Procedure Article 46.05, to forcibly medicate an incompetent death row prisoner so as to make him competent to be executed.
Steven Kenneth Staley, a Texas death row prisoner, was convicted of capital murder and sentenced to be executed. Shortly before his scheduled execution date, the court found him incompetent to be executed because he was suffering from paranoid schizophrenia and did not understand why he was going to be executed. Staley refused to consistently comply with taking the medication haloperidol because he believed the medication was poison. The state then filed a motion to forcibly medicate Staley which the court granted. The medication rendered Staley sufficiently competent that, at a subsequent competency hearing six years later, he was declared competent by the court which set an execution date. Staley appealed and filed a state petition for a writ of habeas corpus.
The Court of Criminal Appeals declined to rule on the issue of whether it was unconstitutional to forcibly medicate an incompetent person so as to execute him. Instead, it found that the current competency-to-be-executed statute applied to this case, said statue permitted Staley’s appeal of the involuntary-medication order and that the trial court lacked authority under the competence-to-be-executed statute to order involuntary medication. In doing so, the Court of Criminal Appeals noted that a trial court’s post-judgment jurisdiction over a case is limited by the statute authorizing said jurisdiction. “A plain reading of the competency-to-be-executed statute indicates that the trial court lacked the authority to order appellant involuntarily medicated….Nothing in the statute permits the trial court, once it has found a defendant incompetent, to take any action other than ordering periodic reevaluation of the defendant.” No other statute authorizes forcibly medicating a death row prisoner so the Court of Criminal Appeals vacated the trial court’s involuntary medication order and also vacated the order finding Staley competent to be executed. See: Staley v. State, 420 S.W.3d 785 (Tex. Crim. App. 2013).
Related legal case
Staley v. State
| Year | 2013 |
|---|---|
| Cite | 420 S.W.3d 785 (Tex. Crim. App. 2013) |
| Level | Court of Appeals |