Dunn v. Reeves

In Dunn v. Reeves, the U.S. Supreme Court on July 2, 2021 vacated an injunction that had halted the execution of Alabama death row inmate Matthew Reeves. Reeves was convicted of the 1996 murder of Willie Johnson. Citing his intellectual disability, Reeves argued that the Americans with Disabilities Act entitled him to choose nitrogen hypoxia over lethal injection, a method Alabama had authorized but required inmates to elect by a deadline. A district court and the Eleventh Circuit issued a preliminary injunction. The Supreme Court, in a 5-4 ruling, lifted the stay, finding that Reeves had not shown a sufficient likelihood of success on the merits. The decision allowed Alabama to proceed with lethal injection. The case exemplified the Court’s approach to late-hour death penalty appeals and the interplay between disability rights and state execution procedures.

The U.S. Supreme Court vacated the stay of execution; Matthew Reeves was executed via lethal injection on January 27, 2022.

Whether a death row inmate’s claim under the Americans with Disabilities Act that he should have been allowed to opt for nitrogen hypoxia over lethal injection met the standard for a preliminary injunction to stay his execution.

The case intensified debate over accommodations for intellectually disabled inmates in capital punishment contexts and highlighted the Supreme Court’s use of its emergency docket to allow executions to proceed, raising concerns about disability rights and procedural fairness.