Killer of 13 too Insane to be Executed

In the "you can't make this shit up" department, we have George Banks. Banks killed 13 people in 1983, including 5 of his own children. A Pennsylvania judge found yesterday, that George Banks is too mentally ill to be executed. At what point does someone do something heinous enough that his mental state is no longer the issue? I think Banks passed that point when he killed 13 people. Just saying. Some crimes are so horrendous that it really doesn't matter why the person did it. 13 people. Dead.