SINGLETON v. NORRIS
Charles Singleton was convicted of first-degree murder in the stabbing death of Mary Lou York, and sentenced to death. Singleton had schizophrenia, and was considered legally sane only when on medication. While in prison, Singleton stopped voluntarily taking his medication. Determining that Singleton was a danger to himself and others, prison officials administered the medication against his will. Singleton appealed, arguing that since taking the medication would cause him to be eligible for execution, the forced medication was no longer in his medical interest, as required by the Supreme Court's due process precedents. Singleton also argued that the Constitution's Eighth Amendment prohibits the execution of an "artificially competent" prisoner. After exhausting Arkansas state remedies, Singleton appealed to a federal District Court, which denied his petition for habeas corpus. On appeal, the Circuit Court of Appeals for the Eighth Circuit rejected Singleton's arguments and reaffirmed his death sentence. The Circuit Court held that since Singleton did not deny that his medication was in his medical interest while the execution was on hold, the forcible administration of medication could not become unconstitutional once an execution date was set. The fact that Singleton's medication would make his execution possible was not to be considered when evaluating "medical interest." The Circuit Court also held that under the Supreme Court’s precedents, the Eighth Amendment only prohibits the execution of actually incompetent prisoners, and not those able to be made competent through medication. Singleton appealed to the Supreme Court.
Does the Eighth Amendment permit a death row inmate - who is legally insane unless taking medication - to be forcibly medicated to the point where he is eligible for execution?
Unanswered. The Court denied Singleton's petition for certiorari, letting the Eighth Circuit's ruling stand. Singleton was executed by the state of Arkansas in 2004.