Gary Gilmore was the first person in the United States to be executed since SCOTUS issued its decision in Gregg v. Georgia, 428 U.S. 153, 96 S. Ct. 2909, 49 L. Ed. 2d 859 (1976),  which reinstated the death penalty in the United States.   It had been almost a decade since anyone had been executed in this country, and the world watched as Gilmore insisted upon death by firing squad in lieu of hanging.

During the current controversy surrounding execution methods in the United States, particularly the issues involved in lethal injection and its drug protocols, some may find it interesting to consider the Gilmore case, where the State of Utah had authorized capital punishment either by hanging or firing squad.  Lethal injection was not an option. The convicted man, under Utah law, had the choice between execution methods.

Norman Mailer wrote his acclaimed non-fiction novel, The Executioner’s Song, based upon the case of Gary Mark Gilmore.  Mailer won the Pulitzer Prize for his efforts.

From a perspective of execution methods,  the later third of this true crime novel focuses upon Gilmore’s fight to avoid continued appeals and move forward to execution.   This is a fact-based read:  Mailer bases his work on case documents and extensive interviews with Gary Gilmore, among others.

Gilmore wanted to die, and fought hard to be executed.  He wanted to die by firing squad.

Mailer’s book is over 1000 pages but it’s a phenomenal read.  For those who may want a shorter read on the subject – or to watch something instead of reading this opus, there is an excellent article written by Lily Rothman and published by Time Magazine on March 12, 2015, entitled “The Strange Story of the Man Who Chose Execution By Firing Squad,” as well as the Biography Channel’s documentary entitled “ Gary Gilmore: Facing the Firing Squad,” available on YouTube.



The death penalty trial of Markeith Loyd for the death of Orlando Police Officer Debra Clayton has been reset by the Honorable Leticia Marques to October 8, 2021, when jury selection will begin in the case of State of Florida vs. Markeith Loyd.  Terence Lenamon serves as defense counsel in this case.

For more information regarding the Loyd case, read our earlier discussions in:

Media coverage of this week’s hearing regarding the new trial setting included Terence Lenamon’s statements during the hearing regarding critical issues involved in this death penalty defense matter.   See, e.g.,Trial date set for Markeith Loyd in killing of Orlando police officer,” written by Holly Bristow and published by FOX-35 Orlando on April 26, 2021.

They include the following, issues which dovetail with national concerns regarding capital cases in this country:

1. Excessive Force by the Police

One defense argument involves excessive force by the police when Mr. Loyd was taken into custody.  Markeith Loyd lost his eye as a result of being kicked in the face by law enforcement.  For more, read Markeith Loyd Death Penalty Trial: Motions Filed Regarding Investigation into Excessive Force During Apprehension.

Also see:

2.  Insanity at the Time of the Incident

Another defense argument involves an insanity defense and Loyd’s position that he was acting in self-defense when Officer Clayton approached him.   For more, read Markeith Loyd Notice of Intent to Rely on Insanity Defense Filed by Terence Lenamon.

The trial is expected to last four to six weeks.









Pennsylvania-based death penalty defense lawyer Marc Bookman currently serves as the Executive Director of the Atlantic Center for Capital Representation, a nonprofit organization providing capital case defense for those facing a possible death penalty sentence and state execution. Before that he advocated for defendants as part of the Defender Association of Philadelphia’s Homicide Unit.

Marc Bookman is also a longstanding, well-respected essayist with published work delving into various death penalty issues appearing in The Atlantic, Mother Jones, VICE, and Slate.

In May 2021, his latest contribution to the fight against capital punishment in this country will be published by The New Press, entitled A Descending Spiral: Exposing the Death Penalty in 12 Essays.

It is also available for pre-order at with a current giveaway promotion ending April 28, 2021, on Goodreads. provides the following editorial reviews:

“Essays from one of America’s most prominent death penalty abolitionists. . . . Bookman creates a clear, comprehensive portrait of a broken system, and the cases he highlights make for fascinating reading.”
Kirkus Reviews

“With lucid prose and a firm grasp of history and legal precedent, Bookman makes a persuasive argument that these dozen cases are just the tip of the iceberg when it comes to death penalty injustices. This is a cogent and harrowing primer on what’s wrong with capital punishment.”
Publishers Weekly

“No one covers the defects of our nation’s criminal justice system more forcefully or eloquently than Marc Bookman.”
Robert Atwan, series editor of The Best American Essays

“In these remarkable essays, Bookman achieves a dispassion that is more incisive and compelling than any overt advocacy. His gift for exquisite irony and his spare, trenchant prose are the perfect tools for exposing the injustices of a legal system that kills haphazardly. Sharpest writing on the death penalty since Koestler and Camus.”
Anthony Amsterdam, university professor emeritus at New York University School of Law

“Bookman’s essays eloquently condemn capital punishment in America. They expose the cruelty and injustice that it imposes on the soul of America and point us toward a healing for which our country yearns.”
Alfre Woodard, actress, producer, and political activist

“Marc Bookman has been writing exquisitely about the cruelty and absurdity of our criminal justice system for years. In this moving series of essays, he weaves in the context and history of our barbaric capital punishment regime and the ways discrimination and bigotry have upheld the system that exists today. A devastating and illuminating book.”
Josie Duffy Rice, president, The Appeal

“As one of America’s premier capital defense attorneys, Bookman has dedicated his life to celebrating the humanity of those citizens we most want to forget. Here, he weaves an unflinching portrait of twelve cases that illustrate in painful detail why the death penalty remains one of the greatest stains on the moral fabric of our society. These essays will make your blood run cold.”
Tony Goldwyn, actor, director, and producer

It is a recommended read.

Death Penalty Law springs out of two wells in two forums:  the judiciary and the legislature, at both the state and federal levels.

Consider the continuing interplay on the  proper implementation of the Florida Death Penalty between SCOTUS and the Florida Supreme Court in Hurst v. State and Poole v. State, as one example.   See, “Florida Supreme Court “Recedes” from Major Death Penalty Decision Creating Uncertainty About Status of Dozens of Cases,” published by the American Bar Association on March 11, 2020.

The power of appellate court decisions to control capital punishment in this country cannot be underestimated.

However, there is also tremendous power in the legislative branch, where new statutes can be passed which can curtail, alter, or end the death penalty as a means of punishment for capital crimes.  An important attempt to create new Florida law regarding capital cases is currently in play up in Tallahassee.

Florida SB 1156 Seeks to End Capital Punishment for Mentally Ill in Florida

In February 2021, two Florida state senators introduced a bill into the Florida Senate that sought to prohibit capital punishment for those convicted in the Sunshine State of a capital offense who were shown to suffer from severe mental illness.  It was filed as Florida Senate Bill 1156.

On March 30, 2021, SB 1156 moved from the Committee on Criminal Justice, with unanimous approval, to the Judiciary Committee for its consideration.

The lawmakers who drafted SB1156 looked to analogous legislation proposed (and passed into law) in the State of Ohio.  They mirrored their bill on that language.  If passed, this new Florida law would prohibit state prosecutors from seeking the death penalty when the accused is shown to have had severe mental illness at the time of the capital offense.

Unfortunately, there was no correlated support in the Florida House for SB1156.  Accordingly, the bill is not expected to succeed in this legislative session, which ends on April 30th, but there are hopes that it will fare better when the Florida Statehouse reconvenes in November.

For more, read “Florida Still Executes the Mentally Ill.  This Bill Would Stop That,” written by Kathryn Varn and published by the Tampa Bay Times on April 19, 2021.

Also see:


SB 1156: Synopsis and Full Text of Proposed Law

SB 1156 is described as follows:

Serious Mental Illness as Bar to Execution; Prohibiting the imposing of a sentence of death upon a defendant convicted of a capital felony if the defendant had a serious mental illness at the time of committing the offense; requiring a defendant to provide a certain notice if he or she intends to raise serious mental illness as a bar to a death sentence; requiring the defendant to file a written motion if he or she intends to raise serious mental illness as a bar to a death sentence; requiring certain court orders if the court finds by clear and convincing evidence that the defendant had a serious mental illness at the time of the commission of the crime, etc.

Authored by Senator Jeff Brandes, the full text of this proposed legislation provides as follows:

 A bill to be entitled                      
    2         An act relating to serious mental illness as bar to
    3         execution; creating s. 921.135, F.S.; defining the
    4         term “serious mental illness”; prohibiting the
    5         imposing of a sentence of death upon a defendant
    6         convicted of a capital felony if the defendant had a
    7         serious mental illness at the time of committing the
    8         offense; requiring a defendant to provide a certain
    9         notice if he or she intends to raise serious mental
   10         illness as a bar to a death sentence; requiring the
   11         defendant to file a written motion if he or she
   12         intends to raise serious mental illness as a bar to a
   13         death sentence; providing motion requirements;
   14         providing for the testing, evaluation, or examination
   15         of the defendant by experts; providing time
   16         limitations for the filing of the motion; requiring
   17         the circuit court to conduct an evidentiary hearing on
   18         the motion; providing court requirements; providing
   19         for waiver of the claim; requiring certain court
   20         orders if the court finds by clear and convincing
   21         evidence that the defendant had a serious mental
   22         illness at the time of the commission of the crime;
   23         authorizing the state to appeal such an order;
   24         providing requirements; providing that the time of
   25         diagnosis does not preclude the defendant from
   26         presenting evidence of a serious mental illness;
   27         prohibiting certain statements of the defendant from
   28         being used against him or her; providing construction;
   29         providing for postconviction proceedings; providing
   30         requirements; providing for stays of certain
   31         proceedings; providing an effective date.
   33         WHEREAS, leading state and national mental health
   34  organizations, including the American Psychological Association,
   35  the American Psychiatric Association, and the National Alliance
   36  on Mental Illness, have called for a prohibition on imposition
   37  of the death penalty for persons with a serious mental illness
   38  at the time of the commission of the crime, and
   39         WHEREAS, the American Bar Association recently endorsed the
   40  call for the end of the death penalty for persons with a serious
   41  mental illness, NOW, THEREFORE,
   43  Be It Enacted by the Legislature of the State of Florida:
   45         Section 1. Section 921.135, Florida Statutes, is created to
   46  read:
   47         921.135 Imposition of death sentence upon defendant with
   48  serious mental illness prohibited.—
   49         (1)DEFINITION.—As used in this section, the term “serious
   50  mental illness” means any mental diagnosis, disability, or
   51  defect that significantly impairs a person’s capacity to do any
   52  of the following: appreciate the nature, consequences, or
   53  wrongfulness of his or her conduct in the criminal offense;
   54  exercise rational judgment in relation to the criminal offense;
   55  or conform his or her conduct to the requirements of the law in
   56  connection with the criminal offense. A disorder manifested
   57  primarily by repeated criminal conduct or attributable solely to
   58  the acute effects of alcohol or other drugs does not, by itself,
   59  constitute a serious mental illness for purposes of this
   60  section. The condition or conditions defined in this section are
   61  a bar to the imposition of the death penalty notwithstanding the
   62  standard established in s. 775.027 for insanity and the criteria
   63  specified in s. 916.12 for establishing competence to proceed.
   66  sentence of death may not be imposed upon a defendant convicted
   67  of a capital felony if it is determined in accordance with this
   68  section that the defendant had a serious mental illness at the
   69  time the criminal offense was committed.
   70         (3)NOTICE REQUIRED.A defendant charged with a capital
   71  felony who intends to raise serious mental illness as a bar to a
   72  death sentence must give notice of such intention in accordance
   73  with the rules of court governing notices of intent to offer
   74  expert testimony regarding mental health mitigation during the
   75  penalty phase of a capital trial.
   78         (a)A defendant who intends to raise serious mental illness
   79  as a bar to execution shall file a written motion to establish
   80  serious mental illness as a bar to execution with the court.
   81         (b)The motion must state that the defendant is seriously
   82  mentally ill and, if the defendant has been tested, evaluated,
   83  or examined by one or more experts, must include the names and
   84  addresses of the experts. Copies of reports containing the
   85  opinions of any experts named in the motion must be attached to
   86  the motion. The court shall appoint an expert chosen by the
   87  state attorney if the state attorney so requests and that expert
   88  shall promptly test, evaluate, or examine the defendant and
   89  submit a written report of any findings to the parties and the
   90  court.
   91         (c)If the defendant has not been tested, evaluated, or
   92  examined by one or more experts, the motion must state that fact
   93  and the court must appoint two experts who shall promptly test,
   94  evaluate, or examine the defendant and submit a written report
   95  of any findings to the parties and the court.
   96         (d)Attorneys for the state and the defendant may be
   97  present at the examinations conducted by court-appointed
   98  experts.
   99         (e)If the defendant refuses to be examined or to fully
  100  cooperate with the court-appointed experts or the state’s
  101  expert, the court may:
  102         1.Order the defense to allow the court-appointed experts
  103  to review all mental health reports, tests, and evaluations by
  104  the defendant’s expert;
  105         2.Prohibit the defense experts from testifying concerning
  106  any tests, evaluations, or examinations of the defendant
  107  regarding the defendant’s serious mental illness; or
  108         3.Order such relief as the court determines to be
  109  appropriate.
  112  determination of serious mental illness as a bar to execution
  113  must be filed no later than 90 days before trial or at such time
  114  as is ordered by the court.
  116  The circuit court shall conduct an evidentiary hearing on the
  117  motion for a determination of serious mental illness. At the
  118  hearing, the court shall consider the findings of the experts
  119  and all other evidence on the issue of whether the defendant is
  120  seriously mentally ill. If the court finds that the defendant is
  121  seriously mentally ill, it shall enter a written order
  122  prohibiting the imposition of the death penalty and setting
  123  forth the court’s specific findings in support of the
  124  determination. The court shall stay the proceedings for 30 days
  125  from the date of rendition of the order prohibiting the death
  126  penalty or, if a motion for rehearing is filed, for 30 days
  127  following the rendition of the order denying rehearing, to allow
  128  the state the opportunity to appeal the order. If the court
  129  determines that the defendant has not established that he or she
  130  is seriously mentally ill, the court must enter a written order
  131  setting forth the court’s specific findings in support of that
  132  determination.
  133         (7)WAIVER.A claim authorized under this section is waived
  134  if it is not timely filed as specified in subsection (5), unless
  135  good cause is shown for the failure to comply with that
  136  subsection.
  138  the court finds by clear and convincing evidence that the
  139  defendant had a serious mental illness at the time he or she
  140  committed the crime, the court must order the case to proceed
  141  without the death penalty as an issue and must enter a written
  142  order that sets forth with specificity the findings of support
  143  for the determination.
  144         (9)APPEAL.—The state may appeal a court order finding that
  145  the defendant is seriously mentally ill, which stays further
  146  proceedings in the trial court until a decision on appeal is
  147  rendered. Appeals must proceed according to Rule 9.140(c),
  148  Florida Rules of Appellate Procedure.
  149         (10)TIME OF DIAGNOSIS.—A diagnosis of the condition or
  150  conditions after the date of commission of the crime with which
  151  the person is charged does not preclude him or her from
  152  presenting evidence that he or she had a serious mental illness
  153  at the time he or she is alleged to have committed the offense.
  154         (11)STATEMENTS OF DEFENDANT.—Any statement that a person
  155  makes in an evaluation or pretrial hearing ordered pursuant to
  156  this section may not be used against the defendant on the issue
  157  of guilt in any criminal action or proceeding.
  158         (12)MITIGATION EXCLUSION.—This section may not be
  159  construed to preclude the defendant from presenting mitigating
  160  evidence of serious mental illness at the sentencing phase of
  161  the trial.
  162         (13)EFFECT ON POSTCONVICTION PROCEEDINGS.If a person to
  163  whom this section applies has completed state postconviction
  164  proceedings, the person may request permission to file a
  165  successive petition for postconviction relief in accordance with
  166  the Florida Rules of Criminal Procedure alleging that the
  167  petitioner is an individual who had a serious mental illness at
  168  the time he or she committed the offense. A request under this
  169  subsection must be filed not later than July 1, 2022. If the
  170  successive petition is authorized, the postconviction court must
  171  proceed under the Florida rules of postconviction relief. If the
  172  postconviction court determines that the petitioner is an
  173  individual with a serious mental illness, it must vacate the
  174  petitioner’s death sentence and impose a sentence of life
  175  imprisonment without parole. This subsection does not preclude
  176  the postconviction court from granting the person any additional
  177  relief to which the person may be entitled based on the merits
  178  of the person’s additional postconviction claims.
  180  EXECUTION; STAY OF EXECUTION.The filing of a motion to
  181  establish serious mental illness as a bar to execution does not
  182  stay further proceedings in the absence of a separate order
  183  staying execution.
  184         Section 2. This act shall take effect July 1, 2021.


Virginia's electric chair
Electric chair at the Virginia Penitentiary in Richmond, Virginia. Designed and installed by Adams Electric Co., Trenton, New Jersey. (Credit: Library of Virginia) (Image provided by State of Virginia in News Release 03/24/21)

On March 24, 2021, the State of Virginia became the 23rd state in the United States to end capital punishment.  The two men who sit on Virginia’s Death Row, Anthony Joiner and Thomas Porter, will have their sentences commuted to LWOP (life without parole).  For more, read “Virginia, with 2nd-most executions, outlaws death penalty,” written by Denise Lavoie and published by the Associated Press on March 24, 2021.

Among the reasons cited by the State of Virginia in its news release yesterday is the issue of race in capital punishment, explaining (emphasis added):

Studies have shown that a defendant is more than three times as likely to be sentenced to death if the victim of a crime is White, than if the victim is Black. In the twentieth century, 296 of the 377 defendants that Virginia executed were Black. Of the 113 individuals who have been executed in Virginia since the Supreme Court reinstated the death penalty in 1976, 52 were Black.

From Virginia Governor Ralph Northam:

“Over our 400-year history, Virginia has executed more people than any other state.  The death penalty system is fundamentally flawed—it is inequitable, ineffective, and it has no place in this Commonwealth or this country. Virginia has come within days of executing innocent people, and Black defendants have been disproportionately sentenced to death. Abolishing this inhumane practice is the moral thing to do. This is a truly historic day for Virginia, and I am deeply grateful to those who have fought tirelessly and for generations to put an end to capital punishment in our Commonwealth.”

For more on issues surrounding the Death Penalty in this country, read:  Six Major Issues Concerning the Death Penalty.



Several different issues must be considered insofar as capital punishment in our country.  The Death Penalty today is a multi-faced concern where considerations must be given to the following:

1.  The Cost of Capital Punishment

For those focused upon finances and taxpayer dollars, the reality is that sentencing someone to death, rather that LWOP (life without parole), is very, very expensive.  LWOP costs less, so why not opt for it? Read:

2.  Lethal Injection and Alternative Execution Methods

Over the centuries, the state has used all sorts of methods to end the life of someone deemed worth of death by those in power.  Today, lethal injection is the common method used in our country to execute the condemned.  However, more and more it is being challenged as cruel and unusual punishment.  States do have options on the books that can substitute for lethal injections without any new legislation; among them, firing squads and gas chambers.  What is the most humane way to execute someone?  For more, see:

3.  Mental Illness and Intellectual Capacity

Mental illness must be considered not only at the time of the crime for which the condemned has been sentenced to die, but also at the time the execution is scheduled to take place.  A similar concept, but distinct from psychological issues, is the lack of understanding and comprehension that goes along with intellectual limitations.  Should someone who is mentally ill or intellectually challenged be executed?  Read:

4.  Race and Gender

Studies time and again reveal that the race of those sitting on our country’s Death Rows does not jive with the racial percentages of our population.  Why not?  And what about gender?  Women on Death Row are another controversial issue to be considered.  Read:

5.  Prosecutors and the Death Penalty

The power of prosecutors in death penalty cases cannot be underestimated.  First, it is the prosecutor who makes the decision to seek capital punishment at the trial level.  Second, it is the prosecutor who tries the case and determines what evidence is presented at trial (both guilt and penalty phases).  Finally, it is the prosecutor who has the ability to sway to results through ineptitude or immorality concerning the underlying investigation and discovery process.  See:

6.  Effective Defense Counsel

Finally, the defense lawyer who represents the individual who is being tried in a case where the state is seeking the Death Penalty has an enormous responsibility.  He or she must advocate in both a guilt-or-innocent trial as well as advancing mitigating factors in any subsequent penalty phase.  It is a tremendous burden, professionally and personally.  There is also the added pressure of financing.  Capital cases demand cost expenditures that quickly add up, from expert analysis for factual issues at trial to mitigating considerations at the sentencing hearing.  Read:

The March 2021 issue of National Geographic may have Mars on the cover, but its article on the death penalty is what drew us to the magazine this month.  Entitled “Sentenced to death, but innocent: These are stories of justice gone wrong,” and written by Phillip Morris, it delves into the shocking realities of innocent people who are nevertheless arrested, charged, convicted, and sentenced to death.  Great photography is included by Martin Schoeller.

Accompanying this work is an explanation from the Nat Geo editor, “Why We Reported on Death Row for the Exonerated,” but this is available only to magazine subscribers.  The Morris piece is free for you to read online.

It’s a recommended read.

This month, the question is raised once again about what the condemned actually experience when undergoing lethal injection, and whether or not this constitutes cruel and unusual punishment. It appears that the executioners’ perspective on what is taking place and those of the execution witnesses may be far, far different.  Read, “Executioners sanitized accounts of deaths in federal cases,” written by Michael Tarm and published by the Associated Press on February 17, 2021.

Pain and Cruel and Unusual Punishment

Of course, as Mr. Tarm points out and as we have discussed earlier, SCOTUS has made it clear that the U.S. Constitution does not provide for a pain-free execution.  The condemned can experience pain without it being in violation of constitutional protections against cruel and unusual punishment.  Read, Painful Executions are not Cruel and Unusual Punishment under the Eighth Amendment.

It’s also important to point out that different lethal executions use different drugs, alone or in combination.  The federal executions involved pentobarbital.  Used alone.

Pentobarbital has been criticized for use in executions because if it is improperly administered, it will cause pain.  And no one is sure its intensity.  Read, “Why the Justice Department’s Plan to Use a Single Drug for Lethal Injections Is Controversial,” written by Josiah Bates and published by Time Magazine on July 29, 2019.

We’ve discussed pentobarbital before.  You may recognize it as the drug that veterinarians commonly use to euthanize beloved pets.  Read, Pentobarbital Supply and Demand for Execution DrugsPentobarbital Shortage in Death Penalty Executions: The Continuing Problem of Finding Drugs for Lethal Injections; and Lethal Injections and Compounding Pharmacies: Why These Are Very Bad Sources of Supply.

How is pentobarbital so painful as to constitute cruel and unusual punishment?

The argument, as described by Justice Sotomayor in her recent dissent in Barr v. Lee, 140 S. Ct. 2590 (2020), is as follows (emphasis added):

In light of this change, respondents alleged that the Government’s planned use of pentobarbital could result in needless pain and suffering in violation of the Eighth Amendment. Among other things, respondents proffered expert evidence that the majority of those injected with pentobarbital suffer flash pulmonary edema, which can lead to a sensation akin to drowning and “`extreme pain, terror, and panic.'” Id., at 10a.


As President Biden takes office, activists against the federal death penalty are hopeful that he will commute the death sentences of those who sit on the Federal Death Row.  See, e.g.,Dems Squad members try to save the worst killers of all: Pressley and Bush demand Biden commutes sentences of all 49 federal prisoners on death row, including Charleston church shooter Dylan Roof and Boston Marathon bomber Dzhokhar Tsarnaev, written by Martin Gould and published by the UK Daily Mail on January 26, 2021.

But what is commutation of a death sentence? And how does it differ from a resentencing hearing?



Commutation is a form of clemency that stops the execution and ends the sentence of death.  It does not change the underlying criminal conviction:  the person is still considered guilty of the crimes for which he was tried and sentenced.  It is not a pardon.

Commutation substitutes a lesser penalty or sentence for that of capital punishment.  The power to commute a death sentence lies with different authorities, depending on the jurisdiction.  Florida, for example, requires the governor to have a recommendation to commute a death sentence from the Florida  Clemency Board before the governor can act.

Constitutionally, commutation is considered a part of the government’s power to pardon someone after they have been sentenced to death.

For more, read:

Resentencing Hearing

A resentencing hearing is a full evidentiary hearing where both the state and the defense present arguments and authorities to the judge who will decide whether to change the death sentence.  As with a commutation, the person is still considered guilty of the crimes for which he was tried and sentenced.

However, after the resentencing hearing the person may no longer face capital punishment.  His sentence may be modified to remove the death penalty.

In Florida, decisions by both the Supreme Court of the United States as well as the Florida Supreme Court have resulted in court-ordered resentencing hearings for many of those residing on Florida’s Death Row.

Terence Lenamon is one of the Florida capital defense lawyers involved in these resentencing hearings. See, e.g.: Florida Supreme Court: How Victory of Lenamon Client Michael James Jackson Impacts Future Death Penalty Defense.

For more on resentencing hearings in Florida, see: “Florida Supreme Court Overturns Precedent Throughout 2020,” published by the American Bar Association Death Penalty Representation Project on January 26, 2021.

Also see: