Defendant’s Competency Confirmed Despite Claim That Experts Ignored Brain Scans
Recent Cases in Law and Neuroscience, Curated by the Center for Law, Brain & Behavior and the Shen Neurolaw Lab with support from the Dana Foundation
On December 20, 2020, Jarvis Wayne Madison, charged with capital murder, was found competent to stand trial in the United States District Court in the Middle District of Florida. Madison had objected to the recommendation in part because the government’s experts did not view his brain scans.
In 2016, Madison was charged with the abduction and killing of his estranged wife.
Madison’s competency had been the subject of several years of litigation.
For this round of evaluations, two government experts, a forensic psychologist and neuropsychologist, each evaluated Madison. They found that he “does not currently suffer from a mental disease or defect that would preclude him from proceeding to trial” and had “generally intact performances across cognitive domains,” although one diagnosed him with narcissistic personality disorder. A third government expert, a psychologist, reviewed the other two experts’ evaluations and agreed with their assessment that he was competent.
Five other experts testified for Madison. One neuropsychologist opined that Madison was incompetent due to a delusional disorder. A second neuropsychologist, a forensic psychiatrist, and a psychologist each examined Madison, and each opined that although Madison was aware of the charges facing him, he was incompetent because he did not fully understand the legal process.
Madison’s objection specifically regarded the testimony of a radiologist. The radiologist found abnormalities in Madison’s brain scans (CT scans, MRIs, and X-rays), including a left parietal hemorrhage, relative cerebellar and frontal lobe hypometabolism, abnormal progressive white matter throughout the brain, a pituitary mass, and abnormal brain volumes. These results, according to the radiologist, indicated head trauma, endocrine dysfunction, and vascular dementia.
The judge at Madison’s competency trial found that he “is suffering from a mental disease or defect — brain damage and vascular dementia” yet recommended the court find him competent to stand trial.
Madison objected. He argued that the competency hearing judge “improperly credited” the government’s experts because they did not find that he had brain damage. The government’s experts did not view Madison’s brain scans because they lacked the software to view them. Madison asserted that “failing to ask for help reading these scans is incontrovertible evidence [the government’s experts] are not credible experts.”
Nevertheless, the court noted that the brain scans showed only structural damage and could not identify any functional deficits. The court said that “while perhaps [the government’s experts] should have arranged to view the scans, they conducted neuropsychological evaluations and forensic assessments to determine Defendant’s functioning,” methodology which is consistent with assessing brain function rather than structure. Because Madison’s brain function was the concern of the competency hearing, the court found that the competency judge did not err in crediting the opinions of the government’s experts.
Finding that “crediting one expert over the other is not arbitrary or clearly erroneous if the record evidence supports the determination,” the court overruled Madison’s objections and found Madison competent to stand trial.
Key words: competency, brain imaging, brain scan, MRI, CT, expert testimony, Florida
Citation: United States v. Madison, 2020 WL 7768460
This post is the 40th post as part of an ongoing Center for Law, Brain & Behavior (CLBB) series tracking the latest developments in law and neuroscience cases. To see previous posts about recent cases, see the full case archive on the CLBB website. To see updates on legal scholarship, see the Neurolaw News, hosted by the MacArthur Foundation Research Network on Law and Neuroscience. This project is made possible through support of the Dana Foundation.
