Capital punishment in the United States

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  States with a valid death penalty statute
  States without the death penalty

Capital punishment is a legal penalty in the United States, currently used by 31 states and the federal government.[1] Its existence can be traced to the beginning of the American colonies.

There were no executions in the entire country between 1967 and 1977. In 1972, the U.S. Supreme Court struck down capital punishment statutes in Furman v. Georgia, reducing all death sentences pending at the time to life imprisonment.[2]

Subsequently, a majority of states passed new death penalty statutes, and the court affirmed the legality of capital punishment in the 1976 case Gregg v. Georgia. Since then, more than 1,400 offenders have been executed, including 28 in 2015.[3]

The United States is the only Western country currently applying the death penalty[4] and was the first to develop lethal injection as method of execution, which has since been adopted by five other countries.[5]


Pre-Furman history[edit]

Executions in the United States from 1608 to 2009

The first recorded death sentence in the British North American colonies was carried out in 1608 on Captain George Kendall,[6] who was executed by firing squad[7] at the Jamestown colony for allegedly spying for the Spanish government.[8]

The Espy file,[9] compiled by M. Watt Espy and John Ortiz Smykla, lists 15,269 people executed in the United States and its predecessor colonies between 1608 and 1991. From 1930 to 2002, there were 4,661 executions in the U.S., about two-thirds of them in the first 20 years.[10] Additionally, the United States Army executed 135 soldiers between 1916 and 1955 (the most recent).[11][12][13]






Nevertheless, capital punishment continued to be used by a majority of states and the federal government for various crimes, especially murder and rape, from the creation of the United States up to the beginning of the 1960s. Until then "save for a few mavericks, no one gave any credence to the possibility of ending the death penalty by judicial interpretation of constitutional law" according to abolitionist Hugo Bedau.[16]


But in the 1932 case Powell v. Alabama, the court had already made the first step of what would be latter called the "death is different" jurisprudence, when it held that any indigent defendant was entitled to a court-appointed attorney in capital cases—a right that was only later extended to non-capital defendants in 1963, with Gideon v. Wainwright.

Capital punishment suspended (1972)[edit]

Further information: Furman v. Georgia
Executions in the United States since 1960



The Furman decision caused all death sentences pending at the time to be reduced to life imprisonment, and was described by scholars as a "legal bombshell".[2] The next day, columnist Barry Schweid wrote that it was "unlikely" that the death penalty could exist anymore in the United States.[17]


Other states adopted "bifurcated" trial and sentencing procedures, with various procedural limitations on the jury's ability to pronounce a death sentence designed to limit juror discretion. The Court clarified Furman in Woodson v. North Carolina[18] and Roberts v. Louisiana,[19] which explicitly forbade any state from punishing a specific form of murder (such as that of a police officer) with a mandatory death penalty.


Capital punishment reinstated (1976)[edit]

Further information: Gregg v. Georgia
U.S. Supreme Court seat in Washington, D.C.




Subsequent history[edit]

The lethal injection room in Florida State Prison.

Executions rose at a near-continuous pace until 1999, when it picked up at 98. After 1999, executions near-continuously lowered every year, and the 28 executions in 2015 were the fewest since 1991.[21][22]


In 1996, Congress passed the Antiterrorism and Effective Death Penalty Act (AEDPA) to streamline the appeal process in capital cases. The bill was signed into law by President Bill Clinton, who had endorsed capital punishment during his 1992 presidential campaign.

The U.S. Supreme Court has placed two major restrictions on the use of the death penalty. First, the case of Atkins v. Virginia, decided on June 20, 2002,[25] held that the execution of mentally retarded inmates is unconstitutional. Second, in 2005, the court's decision in Roper v. Simmons[26] struck down executions for offenders under the age of 18 at the time of the crime. In the 2008 case Kennedy v. Louisiana, the court also held 5–4 the death penalty unconstitutional when applied to non-homicidal crimes against the person including child rape.

In 2004, New York and Kansas capital sentencing schemes were struck down by their respective state highest courts. Kansas successfully appealed the Kansas Supreme Court decision to the United States Supreme Court, who reinstated the statute in Kansas v. Marsh (2006), holding it did not violate the U.S. Constitution. The decision of New York Court of Appeals was instead based on the state constitution, making unavailable any appeal, and the state lower house have since blocked all attempts to reinstate the death penalty by adopting a valid sentencing scheme.[27]

In 2007, New Jersey became the first state to repeal the death penalty by legislative vote since Gregg v. Georgia,[28] followed by New Mexico in 2009,[29][30] Illinois in 2011,[31] Connecticut in 2012,[32][33] and Maryland in 2013.[34] The repeals were not retroactive, but in New Jersey, Illinois and Maryland, governors commuted all death sentences after enacting the new law.[35] In Connecticut, the state top court ruled in 2015 that the repeal must be retroactive, making New Mexico the only state with remaining death row inmates though no present death penalty statute.[36]

Nebraska's legislature also passed a repeal in 2015, but a referendum campaign gathered enough signatures to suspend it, and capital punishment was reinstated by popular vote on November 8, 2016. The same day, California's electorate defeated a proposal to repeal the death penalty, and adopted another initiative to expedite its appeal process.[37]


Because Breyer and Ginsburg are not the first justices to change their minds on that issue, the move led to a scathing retort from Justice Scalia, joined by Justice Thomas, who began his concurring opinion by saying "Welcome to Groundhog Day". He expressed the view that whenever a justice asserts it is now time to judicially abolish the death penalty, he only advances the same contentions that have not convinced the court earlier.[39]

Justice Thomas, joined by Justice Scalia, also wrote a concurring opinion in this case, saying that Breyer and Ginsburg are engaging in the "ceaseless quest to end the death penalty through undemocratic means" and that the court should never have prohibited mandatory death sentences, because they are the best way to impose a uniform death penalty appliance. He felt contradictory that some judges were willing to get rid of the death penalty on the grounds of a sentencing arbitrariness and delays for which the court itself is to blame.[40]

Capital crimes[edit]

Aggravated murder[edit]

All inmates executed since the United States reinstated the death penalty in 1976 were convicted of intentional homicide. In the 1980 case Godfrey v. Georgia, the U.S. Supreme Court ruled that murder can be punished by death only if it involves a narrow and precise aggravating factor.[41]

Such factors allowing prosecution to seek capital punishment vary greatly from one state to one another, California for example having 22,[42] while New Hampshire has only seven.[43] But some aggravating circumstances are nearly universal among death penalty states, such as robbery-murder, murder involving rape of the victim, and murder of an on-duty police officer.[44]


The high number of aggravating factors in some states has been criticized as giving local prosecutors too much discretion in picking cases were they believe capital punishment warranted. In California especially, an official commission proposed in 2008 to reduce them to only five (multiple murders, torture murder, murder of a police officer, murder committed in jail, and murder related to another felony).[46] Columnist Charles Lane went further, and proposed that murder related to a felony other than rape should no longer be a capital crime when there is only one victim killed.[47]

Other crimes against persons[edit]

In June 2008, the U.S. Supreme Court held 5–4 in Kennedy v. Louisiana that the death penalty cannot be imposed for non-homicidal crimes against the person. In this case, it struck down a Louisiana statute providing capital punishment for raping a child under the age of 12. Only two death row inmates (both in Louisiana) have been affected by the decision.[48] Nevertheless, the ruling came less than five months before the 2008 presidential election and was criticized by both major party candidates Barack Obama and John McCain.[49]

Numerous states still have on their statutes books various provisions allowing the death penalty for child rape or other non-homicidal crimes such as kidnapping.[50]

Crimes against the state[edit]



Treason, espionage and large-scale drug trafficking are all capital crimes under federal law. Treason is also a punishable by death in six states (Arkansas, California, Georgia, Louisiana, Mississippi and Missouri) and large-scale drug trafficking in two states (Florida and Missouri).[50] Vermont still have a pre-Furman statute providing the death penalty for treason.[52]

Legal process[edit]

The legal administration of the death penalty in the United States, typically, it involves five critical steps: (1) prosecutorial decision to seek the death penalty (2) sentencing, (3) direct review, (4) state collateral review, and (5) federal habeas corpus.


Decision to seek the death penalty[edit]



A proposed remedy against prosecutorial arbitrariness is to transfer the prosecution of capital cases to a statewide prosecution office or to the state attorney general.[55]


Of the 31 states using the death penalty, three (Alabama, Montana and Nebraska) provide the sentence to be decided by one or three judges when the prosecution seeks capital punishment (with a jury nonbinding advice in Alabama).

The 28 other states provide the sentence to be decided by a jury, and 27 of them require a unanimous sentence. However, the states differ on what happens if the penalty phase results in a hung jury:[56]

  • In 4 states (Arizona, California, Kentucky and Nevada), a retrial of the penalty phase will happen before another jury (the common law rule for mistrial).[57]
  • In the 21 other states, a hung jury results in a life sentence, even if a single juror opposed death. Federal law also provides that outcome.

In 2016, Florida adopted a statute providing a 10 jurors supermajority to impose a death sentence, but it was struck down by the state supreme court the same year, holding that a jury can issue such sentence only unanimously (see Capital punishment in Florida).[58][59][60][61][62][63]

In Nebraska, the only state in which the sentence is decided by a three-judge panel, a life sentence is handed down even if only one of the three judges opposed death.

In all states in which the jury is involved, only death-qualified veniremen can be selected in such a jury, to exclude both people who will always vote the death sentence and those who are categorically opposed to it.

Direct review[edit]

If a defendant is sentenced to death at the trial level, the case then goes into a direct review.[64] The direct review process is a typical legal appeal. An appellate court examines the record of evidence presented in the trial court and the law that the lower court applied and decides whether the decision was legally sound or not.[65] Direct review of a capital sentencing hearing will result in one of three outcomes. If the appellate court finds that no significant legal errors occurred in the capital sentencing hearing, the appellate court will affirm the judgment, or let the sentence stand.[64] If the appellate court finds that significant legal errors did occur, then it will reverse the judgment, or nullify the sentence and order a new capital sentencing hearing.[66] Lastly, if the appellate court finds that no reasonable juror could find the defendant eligible for the death penalty, a rarity, then it will order the defendant acquitted, or not guilty, of the crime for which he/she was given the death penalty, and order him sentenced to the next most severe punishment for which the offense is eligible.[66] About 60 percent survive the process of direct review intact.[67]

State collateral review[edit]


In Virginia, state habeas corpus for condemned men are heard by the state supreme court under exclusive original jurisdiction since 1995, immediately after direct review by the same court.[72] This avoids any proceeding before the lower courts, and is in part why Virginia has the shortest time have average between death sentence and execution (less than 8 years)[73] and has executed 111 offenders since 1976 with only 7 remaining on death row as of March 2016.[74]

Federal habeas corpus[edit]



A similar process is available for prisoners sentenced to death by the judgment of a federal court.[78]

The AEDPA also provides an expeditious habeas procedure in capital cases for states meeting several requirements set forth in it concerning counsel appointment for death row inmates (28 USC §§ 2261 – 2266). Under this program, federal habeas corpus for condemned men would be decided in less than three years from affirmance of the sentence on state collateral review. In 2006, Congress conferred the determination of whether a state fulfil the requirements to the U.S. attorney general, with a possible appeal of the state to the D.C. circuit appeal court. As of March 2016, the Department of Justice has still not granted any certifications.[79]

Section 1983[edit]




Execution warrant[edit]



Distribution of sentences[edit]




Among states[edit]



Among races[edit]

African Americans made up 41 percent of death row inmates while making up only 12.6 percent of the general population. (They have made up 34 percent of those actually executed since 1976.)[86] However, that number is lower than that of prison inmates, which is 47 percent.[87] According to the US Department of Justice, African Americans accounted for 52.5% of homicide offenders from 1980 to 2008, with whites 45.3% and Native Americans and Asians 2.2%. This means African Americans are less likely to be executed on a per capita basis.[88] However, according to a 2003 Amnesty International report, blacks and whites were the victims of murder in almost equal numbers, yet 80 percent of the people executed since 1977 were convicted of murders involving white victims.[86] 13.5% of death row inmates are of Hispanic or Latino descent, while they make up 17.4% of the general population.[89]

Among sexes[edit]

As of October 1, 2014:[90]

  • men account for 98.12 percent (2,978) of the persons currently on death row, while women account for 1.88 percent (57).
  • men account for 98.92 percent (1,374) of the persons executed since 1976, while women account for 1.08 percent (15).


Usage of lethal injection in the US.
  State uses only this method.
  State uses this method primarily but also has other methods.
  State once used this method, but does not today.
  State once adopted this method, but dropped before its use.
  State has never adopted this method.


Several states continue to use the historical three-drug protocol: an anesthetic, pancuronium bromide a paralytic, and potassium chloride to stop the heart.[91] Eight states have used a single-drug protocol, inflicting only an overdose of a single anesthetic to the prisoner.[91]


Pressures from anti-death penalty activists and shareholders[92] have since made it difficult for correctional services to get the chemicals, and most states have made it a criminal offense to reveal the identities of execution team members or furnishers of lethal injection drugs to avoid this.[93] In 2015 imports of sodium thiopental for Texas and Arkansas from an Indian supplier not approved for the U.S. were seized by federal officials at airports.[92]

Hospira, the only U.S. manufacturer of sodium thiopental, stopped making the drug in 2011. Since then, some states have used other barbiturates, such as pentobarbital or midazolam.[94] In 2016 it was reported that more than 20 U.S. and European drug manufacturers including Pfizer (the owner of Hospira) had taken steps to prevent their drugs from being used for lethal injections.[92]

In November 2015, California adopted regulations allowing the state to use its own public compounding pharmacies to make the chemicals.[95] Some states allow other methods than lethal injection, but only as secondary methods to be used merely at the request of the prisoner or if lethal injection is unavailable.

From 1976 to January 1, 2016, there were 1,422 executions, of which 1,247 were by lethal injection, 158 by electrocution, 11 by gas inhalation, 3 by hanging, and 3 by firing squad.

Lethal injection has been held constitutional by the U.S. Supreme Court two times in Baze v. Rees (2008) and Glossip v. Gross (2015).

Offender-selected methods[edit]

In the following states, death row inmates with an execution warrant may choose to be executed by:[96][97]


When an offender chooses to be executed by a mean different from the state default method, which is always lethal injection, he loses the right to challenge its constitutionality in court (Stewart v. Lagrand, 1999).


Method Date State Convict
Electrocution January 16, 2013 Virginia Robert Gleason
Firing squad June 18, 2010 Utah Ronnie Lee Gardner
Lethal gas March 3, 1999 Arizona Walter LaGrand
Hanging January 25, 1996 Delaware William Bailey

Backup methods[edit]

Depending on the state, the following alternative methods are statutorily provided in the event that lethal injection is either found unconstitutional by a court or unavailable for practical reasons:[96][97][98]

  • Electrocution in Florida, Oklahoma, South Carolina and Tennessee.
  • Gas inhalation in California, Missouri, Oklahoma and Wyoming.
  • Hanging in New Hampshire.
  • Firing squad in Oklahoma and Utah.



Florida and Tennessee have the largest provisions dealing with execution methods unavailability, requiring their state departments of corrections to use "any constitutional method" if both lethal injection and electrocution are found unconstitutional. This was designed to make unnecessary any further legislative intervention in that event, but the provisions apply only to legal (not practical) infeasibility.[101][102]

In May 2016, an Oklahoma grand jury recommended the state to use nitrogen hypoxia as its sole method of execution rather than as a mere backup, after experts testified that the method would be painfree, easy and "inexpensive".[103]

Federal executions[edit]


For offenses under the Drug Kingpin Act of 1988 or the Uniform Code of Military Justice, the method of execution is lethal injection.

Execution attendance[edit]

The around 300 witnesses to the execution of Timothy McVeigh were mostly individuals related to the victims of the Oklahoma City bombing.




But nearly all states allow news reporters to be execution witnesses for information of the general public.[105] Several states also allow victims' families and relatives selected by the prisoner to watch executions. An hour or two before the execution, the condemned is offered religious services and a last meal (except in Texas).


Public opinion[edit]

Gallup, Inc. monitors support for the death penalty in the United States since 1937 by asking "Are you in favor of the death penalty for a person convicted of murder". The last poll in October 2016 gave 60% in favor and 37% opposed.[106] A month earlier, a Pew Research poll found that 49% of Americans supported the death penalty for convicted murderers and 42% opposed, down from 80% in 1974 and the lowest support in 40 years.[107]

When given a choice between the death penalty and life without parole, support has traditionally been significantly lower than polling which has only mentioned the death penalty. In 2010, for instance, one poll showed 49% favoring the death penalty and 46% favoring life imprisonment,[108] while in another 61% said they preferred another punishment to the death penalty.[109]

On the other hand, in November 2009, another Gallup poll found that 77% of Americans say that September 11 attacks' mastermind Khalid Sheikh Mohammed should get the death penalty if convicted, including 12 who normally opposed death penalty when asked the 1937 question.[110] A similar result was found in 2001 when respondents were polled about the execution of Timothy McVeigh for the Oklahoma City Bombing that killed 168 victims.[111]



The United States is one of only five industrialized democracies that still practice capital punishment. From the others, Japan, Singapore, and Taiwan have executed prisoners, while South Korea currently has a moratorium in effect.

Religious groups are widely split on the issue of capital punishment.[112] The Fiqh Council of North America, a group of highly influential Muslim scholars in the United States, has issued a fatwa calling for a moratorium on capital punishment in the United States until various preconditions in the legal system are met.[113]



Arguments for and against capital punishment are based on moral, practical, and religious grounds. Advocates of the death penalty argue that it deters crime, is a good tool for prosecutors (in plea bargaining for example),[117] improves the community by eliminating recidivism by executed criminals, provides closure to surviving victims or loved ones, and is a just penalty for the crimes it punishes.

Opponents argue that the death penalty is not an effective means of deterring crime,[118] risks the execution of the innocent, is unnecessarily barbaric in nature, cheapens human life, and puts a government on the same base moral level as those criminals involved in murder.[119] Furthermore, some opponents argue that the arbitrariness with which it is administered and the systemic influence of racial, socio-economic, geographic, and gender bias on determinations of desert make the current practice of capital punishment immoral and illegitimate.[120]

Another argument (specific to the United States) in the capital punishment debate is the cost. The convict is more likely to use the whole appeals process if the jury issues a death sentence, than if it issues life without parole.[121] But, others, who contest this argument, say that the greater cost of appeals where the prosecution does seek the death penalty is offset by the savings from avoiding trial altogether in cases where the defendant pleads guilty to avoid the death penalty.[122]



Clemency and commutations[edit]



Suicide on death row and volunteering for execution[edit]


Since the reinstitution of the death penalty to January 1, 2016, 143 prisoners have waived their appeals and asked that the execution be carried out. Four states (Connecticut, New Mexico, Oregon, and Pennsylvania) have executed only volunteers in the post-Furman era.[127]

Execution hiatus[edit]

All executions were suspended through the country between September 2007 and April 2008, when the U.S. Supreme Court was examining the constitutionality of lethal injection in Baze v. Rees, something unprecedented. It is the longest period with zero executions in the United States from 1982 to date. The method was ultimately upheld by a 7–2 margin.

In addition to the states that have no valid death penalty statute, the following states and jurisdictions have an official moratorium, or no executions for more than five years, as of 2016:

State / Jurisdiction Status Hiatus status[128]
Arkansas de facto In 2012, state supreme court ruled current law unconstitutional
California de facto No executions since 2006[129]
Florida de facto In October 2016, state supreme court ruled current law unconstitutional
Indiana de facto Last execution took place in 2009
Kentucky by court order In 2010, a federal judge suspended executions pending a new protocol[130]
Louisiana de facto Last execution took place in 2010
Nevada de facto All executions halted due to lethal injection problems
Pennsylvania by Governor In 2015, Governor announced a moratorium pending review
Tennessee de facto Last execution took place in 2009

Since the reinstatement of the death penalty, Kansas, New Hampshire, and the United States military have performed no executions. But in these jurisdictions, and in Wyoming, the lack of recent executions is caused by the absence of any condemned having yet exhausted the appeal process.






Pharmaceutical companies whose products are used in the three-drug cocktails for lethal injections are predominantly European, and they have strenuously objected to the use of their drugs for executions and taken steps to prevent their use.[135] For example, Hospira, the sole American manufacturer of sodium thiopental, the critical anesthetic in the three-drug cocktail, announced in 2011 that it would no longer manufacture the drug for the American market, in part for ethical reasons and in part because its transfer of sodium thiopental manufacturing to Italy would subject it to the European Union's Torture Regulation, which forbids the use of any product manufactured within the Union for torture (as execution by lethal injection is considered by the Regulation).[136] Since the drug manufacturers began taking these steps and the EU regulation ended the importation of drugs produced in Europe, the resulting shortage of execution drugs has led to or influenced decisions to suspend executions in Arkansas, California, Kentucky, Louisiana, Mississippi, Montana, Nevada, North Carolina, and Tennessee.[135]



In May 2014, Oklahoma Director of Corrections, Robert Patton, recommended an indefinite hold on executions in the state after the botched execution of Clayton Lockett.

On February 13, 2015, Pennsylvania Governor Tom Wolf announced a moratorium on the death penalty. Wolf will issue a reprieve for every execution until a commission on capital punishment that was established in 2011 by the Pennsylvania State Senate produces a recommendation.[140]

See also[edit]


  1. ^ "Death penalty repeal officially on hold until 2016 election". Retrieved May 2, 2016. [permanent dead link]
  3. ^ "Execution Statistics Summary -- State and Year". Retrieved March 16, 2016. 
  5. ^ "Lethal injection.". Retrieved March 16, 2016. 
  7. ^ david waksman. "Is there a Death Penalty in America?". 
  9. ^ "Espy file". Retrieved December 1, 2011. 
  10. ^ Department of Justice of the United States of America
  12. ^ John A. Bennett
  13. ^ "Executions in the Military". Retrieved December 1, 2011. 
  16. ^ The Courts, the Constitution, and Capital Punishment 118 (1977)
  18. ^ Woodson v. North Carolina, 428 U.S. 280 (1976)
  20. ^ Gregg v. Georgia, 428 U.S. 153 (1976)
  21. ^ Hananel, Samuel (December 16, 2015). "Executions at Lowest Level Since 1991; Death Sentences Fall". ABC News. Associated Press. Retrieved December 23, 2015. 
  22. ^ Von Drehle, David (June 8, 2015). "The Death of the Death Penalty". Time Magazine. USA: Time Inc. Retrieved July 3, 2015. 
  23. ^ "Obama's non-Dukakis answer". Retrieved April 8, 2016. 
  24. ^ InsidePolitics. "Candidate Ads: 1988 George Bush "Revolving Door"". Retrieved October 29, 2006. 
  29. ^ (English) Maria Medina, « Governor OK with Astorga capital case »
  35. ^ "Clemency". Retrieved April 6, 2016. 
  41. ^ "Godfrey v. Georgia". Retrieved March 24, 2016. 
  42. ^ "Homicide - Section 190.2.". Retrieved March 24, 2016. 
  53. ^ See generally Separation of powers.
  57. ^ See United States v. Perez, 1824
  58. ^ "HB 7101". Florida State Senate. Retrieved March 15, 2016. 
  59. ^ Klas, Mary Ellen (June 14, 2016). "Gov. Rick Scott signs bill to speed up executions in Florida". Miami Herald. Retrieved October 15, 2016. 
  60. ^ Liptak, Adam (January 12, 2016). "Supreme Court Strikes Down Part of Florida Death Penalty". The New York Times. Retrieved February 3, 2016. 
  61. ^ Alvarez, Lizette (February 2, 2016). "Supreme Court Ruling Has Florida Scrambling to Fix Death Penalty Law". The New York Times. Retrieved February 3, 2016. 
  62. ^ Berman, Mark (March 7, 2016). "Florida death penalty officially revamped after Supreme Court struck it down". Washington Post. Retrieved August 3, 2016. 
  63. ^ Klas, Mary Ellen; Ovalle, David (October 14, 2016). "Court again tosses state death penalty; ruling raises bar on capital punishment". Miami Herald. Retrieved October 15, 2016. 
  65. ^ See generally Appeal.
  73. ^ "VIRGINIA'S EXECUTION HISTORY". Retrieved March 22, 2016. 
  75. ^ House v. Bell, 126 S. Ct. 2064 (2006)
  78. ^ see 28 U.S.C. § 2255.
  87. ^ Death Penalty in Black and White Archived December 19, 2003, at the Wayback Machine. (1999 figures).
  88. ^ Cooper, Alexia (2012). Homicide Trends in the United States, 1980–2008. p. 3. ISBN 1249573246. 
  96. ^ a b "Methods of Execution". Retrieved March 28, 2016. 
  97. ^ a b "Methods of Execution". Retrieved March 28, 2016. 
  112. ^ "ReligiousTolerance". ReligiousTolerance. Retrieved December 1, 2011. 
  113. ^ [1][dead link]
  119. ^ American Justice Volume 1
  127. ^ []
  128. ^ "Death penalty flux". March 23, 2015. Retrieved April 25, 2015. 
  135. ^ a b Algar, Clare (October 22, 2013). "Big Pharma May Help End The Death Penalty". The New Republic. Retrieved November 5, 2013. 
  137. ^ Hobbs v. Jones, 412 S.W.3d 844, 854–55 (Ark. 2012).

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Journal articles[edit]

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