Scott Panetti, Prisoner in Landmark Competency Case, Dies on Texas Death Row of Natural Causes

Scott Panetti died on Texas’ death row at the end of May 2025 after 30 years in prison. He became well-known for the role his case played in clar­i­fy­ing the legal stan­dard for deter­min­ing when defen­dants are com­pe­tent to face exe­cu­tion — prece­dent that con­tin­ues to shape court decisions nationwide.

Mr. Panetti’s severe men­tal ill­ness man­i­fest­ed in his late teens, lead­ing to more than a dozen psy­chi­atric hos­pi­tal­iza­tions through the 1980s and ear­ly 1990s. His doc­u­ment­ed con­di­tions includ­ed schiz­o­phre­nia, para­noid delu­sions, and audi­to­ry hal­lu­ci­na­tions. Medical records from mul­ti­ple facil­i­ties, includ­ing Kerrville State Hospital, detailed his elab­o­rate delu­sion­al beliefs, includ­ing con­spir­a­cy the­o­ries and the devel­op­ment of multiple personalities.

In September 1992, a month after out­pa­tient treat­ment revealed his wors­en­ing men­tal state, Mr. Panetti shaved his head, donned mil­i­tary fatigues, and drove to the home of his estranged in-laws, Joe and Amanda Alvarado. Breaking into their home, he shot both of them and took his estranged wife and young daugh­ter to a bunkhouse where he had been liv­ing, though he even­tu­al­ly let them go unharmed. He sur­ren­dered to the police lat­er the same day. Mr. Panetti’s state­ments to the police revealed the depth of his delu­sions: he claimed that ​“Sarge,” an audi­to­ry hal­lu­ci­na­tion, had con­trolled his actions dur­ing the mur­ders. According to Mr. Panetti, divine inter­ven­tion pre­vent­ed either of the vic­tims from suf­fer­ing, and demons mocked him while flee­ing the crime scene.

Despite sig­nif­i­cant con­cerns about his men­tal state, includ­ing con­flict­ing expert opin­ions, a jury ulti­mate­ly found him com­pe­tent to stand tri­al. At his 1995 tri­al, Mr. Panetti, who had stopped tak­ing his med­ica­tion, waived his right to coun­sel and insist­ed on rep­re­sent­ing him­self, despite his well-doc­u­ment­ed psy­chi­atric his­to­ry and over the objec­tions of his fam­i­ly and defense coun­sel. Dressed as a TV-Western cow­boy, Mr. Panetti con­duct­ed his own defense and attempt­ed to sub­poe­na fig­ures includ­ing Jesus Christ and President John F. Kennedy, among hun­dreds of oth­ers. The tri­al was described as a ​“cir­cus” and ​“a farce” by legal observers. The jury con­vict­ed him of cap­i­tal mur­der and sen­tenced him to death.

In 2004, Texas issued a death war­rant seek­ing to exe­cute Mr. Panetti. His coun­sel moved to halt his exe­cu­tion because he was incom­pe­tent and the Constitution ​“for­bade the exe­cu­tion upon the insane.” After fail­ing to tran­scribe court pro­ceed­ings and deny­ing Mr. Panetti’s coun­sel the assis­tance of a men­tal health expert, the tri­al court appoint­ed its own experts to eval­u­ate Mr. Panetti and denied his incom­pe­ten­cy claim with­out a hear­ing. On appeal, Texas fed­er­al courts stayed Mr. Panetti’s exe­cu­tion, grant­ed fund­ing for defense men­tal health experts, and con­duct­ed an evi­den­tiary hear­ing at which he was again found com­pe­tent. The court applied the legal stan­dard that had been set by the U.S. Court of Appeals for the Fifth Circuit that ​“require[d] the peti­tion­er know no more than the fact of his impend­ing exe­cu­tion and the fac­tu­al pred­i­cate for exe­cu­tion.” The Fifth Circuit affirmed.

In its land­mark rul­ing in Panetti v. Quarterman in 2007, the U.S. Supreme Court reversed, hold­ing that the state court com­pe­ten­cy pro­ceed­ings had vio­lat­ed Mr. Panetti’s right to due process and that the fed­er­al court had applied the wrong test for deter­min­ing com­pe­ten­cy. ​“A prisoner’s aware­ness of the State’s ratio­nale for an exe­cu­tion is not the same as a ratio­nal under­stand­ing of it,” Justice Anthony Kennedy wrote for the 5 – 4 major­i­ty (empha­sis added). The Court returned the case to the low­er fed­er­al courts to deter­mine whether the delu­sions from Mr. Panetti’s psy­chot­ic dis­or­der ​“so impair[ed his] con­cept of real­i­ty that he can­not reach a ratio­nal under­stand­ing of the rea­son for the execution.”

On remand, the Texas dis­trict court again denied Mr. Panetti’s incom­pe­ten­cy claim, and the U.S. Supreme Court declined to review that rul­ing. In 2014, Texas sched­uled a new exe­cu­tion date, but the Fifth Circuit issued a stay and ordered a full hear­ing on Mr. Panetti’s com­pe­ten­cy. In his open­ing state­ment to the dis­trict court dur­ing this October 2022 pro­ceed­ing, Gregory Wiercoch, Mr. Panetti’s attor­ney, not­ed, ​“It is unprece­dent­ed to be lit­i­gat­ing on an exe­cu­tion com­pe­ten­cy claim for 20 years[.]”

In September 2023, the U.S. District Court for the Western District of Texas ruled that Mr. Panetti was not com­pe­tent to be exe­cut­ed, find­ing that his severe men­tal ill­ness ren­dered him unable to meet the ​“ratio­nal under­stand­ing” stan­dard his case had estab­lished. The rul­ing was the cul­mi­na­tion of decades of lit­i­ga­tion by legal advo­cates and sup­port­ers to pre­vent Mr. Panetti’s exe­cu­tion. ​“There are sev­er­al rea­sons for pro­hibit­ing the exe­cu­tion of the insane, includ­ing the ques­tion­able ret­ribu­tive val­ue of exe­cut­ing an indi­vid­ual so wracked by men­tal ill­ness that he can­not com­pre­hend the ​‘mean­ing and pur­pose of the pun­ish­ment,’ as well as society’s intu­ition that such an exe­cu­tion ​‘sim­ply offends human­i­ty.’ Scott Panetti is one of these indi­vid­u­als,” wrote Judge Robert Pitman.

Mr. Panetti remained on death row until his death on May 26, 2025.