Bucklew v. Precythe

Russell Bucklew was sentenced to death for the 1996 murder of Michael Sanders. He suffered from a rare medical condition called cavernous hemangioma, arguing that Missouri's lethal injection protocol using pentobarbital would cause him to choke on his own blood and endure severe suffering. He sought to require the state to use nitrogen hypoxia as an alternative execution method. The case reached the U.S. Supreme Court, which ruled in a 5-4 decision on April 1, 2019. Justice Neil Gorsuch wrote for the majority, holding that the Eighth Amendment does not guarantee a condemned inmate an alternative method of execution unless the inmate can identify a feasible and readily implemented alternative that would significantly reduce a substantial risk of severe pain. The Court found Bucklew failed to meet this burden and that his late-stage challenge was an attempt to delay justice.

The Supreme Court affirmed the lower court's ruling in a 5-4 decision, holding that Bucklew failed to satisfy the standard for an alternative execution method. Bucklew was executed via lethal injection on October 1, 2019.

Whether the Eighth Amendment requires a state to adopt an alternative method of execution proposed by a condemned inmate who claims the state's lethal injection protocol will cause severe suffering due to a unique medical condition.

The decision clarified the high burden of proof for inmates challenging execution methods and curtailed last-minute litigation strategies, reinforcing states' authority to carry out death sentences. It prompted renewed debate over the humaneness and constitutionality of executing individuals with serious medical conditions.