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November 3, 2007

Judicial Conference urges retroactivity of new crack guidelines

Adding a very significant voice in the debate over making the US Sentencing Commission's new crack guidelines retroactive, the Criminal Law Committee of the Judicial Conference has sent a thoughtful and powerful letter to the USSC supporting retroactivity.  This detailed letter (which was authored by Judge Paul Cassell on his last day as a judge) can be downloaded below.  Here is the opening paragraph:

I am writing on behalf of the Judicial Conference’s Criminal Law Committee to recommend to the Sentencing Commission that its amendment lowering cocaine base (i.e., “crack” cocaine) penalties apply retroactively.  While concerned about the impact that retroactivity may have on the safety of communities, a majority of the Committee believes that the Commission’s precedents, and a general sense of fairness, dictate retroactive application.  The Committee also believes that the burden to the courts and probation officers associated with resentencings is not a sufficiently countervailing consideration.  The Committee’s recommendation rests on the hope that the Commission will implement procedures to reduce the administrative burden on the federal judiciary associated with the resentencings that would attend retroactive application. The Committee is prepared to help develop and implement such procedures and respectfully suggests that the Commission do what it can to put them in place before applying its amendment retroactively.

Download clc_letter_re_crack_retroactivity.pdf

Some related guidelines retroactivity posts:

November 3, 2007 in New USSC crack guidelines and report | Permalink | Comments (1) | TrackBack

November 2, 2007

Some weekend reading from SSRN

For those looking for a bit of not-so-light weekend reading, now up on SSRN are these new pieces of interest for sentencing fans:

UPDATE:  Scott at Grits has this terrific review of Russell Covey's article on plea bargaining.  The full review is a must-read, and here is how it ends:

I think there needs to be a renewed debate over the ubiquitous role of plea bargains in modern criminal jurisprudence, and I applaud Covey for examining the absurdist legal and economic theories used to justify undermining defendants' constitutional right to trial.  Unfortunately, law review treatises filled with legalese and academic jargon won't be what sparks such a debate.  I'm glad to see folks in the academy examining such topics, but I wish they'd learn to communicate what they find in more publicly accessible ways. These topics are too important not to let the public in on the discussion.

November 2, 2007 in Recommended reading | Permalink | Comments (0) | TrackBack

More dialoging about Danforth

Ann Althouse with a new post here and Orin Kerr with a follow-up here have taken the discussion of the Danforth state retroactivity case to the next level.  Lots of good insights here, and yet I think both are only beginning to peel off some of the many layers to be found in this SCOTUS onion.

Some related posts:

November 2, 2007 in Who Sentences? | Permalink | Comments (0) | TrackBack

A potent (and pernicious?) new claim in the death penalty deterrence debate

Thanks to this post at C&C, I see that Roy Adler and Michael Summers of Pepperdine University have this Wall Street Journal commentary discussing a potent new deterrence claim.  The piece is entitled "Capital Punishment Works," and here are excerpts:

Most commentators who oppose capital punishment assert that an execution has no deterrent effect on future crimes. Recent evidence, however, suggests that the death penalty, when carried out, has an enormous deterrent effect on the number of murders.  More precisely, our recent research shows that each execution carried out is correlated with about 74 fewer murders the following year.

For any society concerned about human life, that type of evidence is something that should be taken very seriously....  The conclusion that each execution carried out is associated with the saving of dozens of innocent lives creates an extraordinarily difficult moral dilemma for those who campaign against the death penalty.  Until now, those activists could look into the eyes of a convicted killer, hear his or her sad story, work tirelessly to set aside the execution and, with that goal accomplished, feel good about themselves for having "saved a life."  These data suggest that the moral equation is not nearly that simplistic.

It now seems that the proper question to ask goes far beyond the obvious one of "do we save the life of this convicted criminal?" The more proper question seems to be "do we save this particular life, at a cost of the lives of dozens of future murder victims?"  That is a much more difficult moral dilemma, which deserves wide discussion in a free society.

The remarkable assertion that each execution could be saving 74 lives creates a stunning new math as the current de facto moratorium unfolds.  Specifically, since cert was granted in Baze, roughly 15 executions have been stayed.  Are the authors of this commentary prepared to assert that the Supreme Court's handiwork may be costing the lives of over 1000 future murder victims?  Indeed, given that de facto moratorium seems likely to delay or prevent many dozens of executions, are the authors of this commentary prepared to suggest that the moratorium could end up costing more lives than the 9/11 tragedies?

As detailed here, I tend to be agnostic about the deterrence debate. But the suggestion in this commentary that every execution could be saving 74 lives seems bold to the point of recklessness.  (Before this commentary, the boldest assertion I saw in the literature was that each execution might save 18 lives.)   I don't know much about Professors Adler and Summers, but I would like to hear more about their study and how far they might be willing to push their conclusions.

Some related death penalty deterrence posts:

November 2, 2007 in Death Penalty Reforms | Permalink | Comments (18) | TrackBack

Are most 1/3 downward variances reasonable, while most larger ones aren't?

Two very interesting sentencing cases decided by the Eighth Circuit have me wondering this reasonableness rule of thumb may exist in the Eighth Circuit and elsewhere: most downward variances of 1/3 or less from the bottom of the applicable range are presumptively reasonable, while larger one presumptively are not.  Here are the unofficial summaries of the two Eighth Circuit decisions that have me thinking about this reasonableness rule of thumb:

Of course, these two cases alone do not indicate that the Eighth Circuit or other circuits have a 1/3 variance reasonableness rule of thumb.  However, I have a sense that most downward variances of 1/3 or less are not even appealed and most get upheld absent a real problematic rationale.  And, conversely, I sense that many appealed downward variances greater than 1/3 are reversed absent a real compelling rationale.

November 2, 2007 in Booker in the Circuits | Permalink | Comments (0) | TrackBack

Debate over retroactive application of new crack guidelines

This New York Times article spotlights that the Department of Justice officially opposes making the US Sentencing Commission's new crack guidelines retroactive:

Department of Justice officials said yesterday that applying the new guidelines retroactively would erode federal drug enforcement efforts and undermine Congress’s role in creating sentencing policy. “The commission is now considering applying the changes retroactively, something that Congress has not suggested in any of the pending bills,” wrote a department spokesman, Peter Carr. “As we state in a letter filed with the commission today, we believe this would be a mistake, having a serious impact on the safety of our communities and impose an unreasonable burden upon our judicial system.”

Meanwhile, Harlan Protass has this op-ed in the Los Angeles Times making the case for retroactivity.  Here is how it ends:

Opportunities to neatly turn back time on social injustices are rare. The new crack sentencing scheme presents one such chance.  The Sentencing Commission should take advantage of this opening. To do otherwise is to compound the mistakes made when Congress first introduced harsh penalties for crack offenses.

Some related guidelines retroactivity posts:

UPDATE:  The Drug War Chronicle now has this effective feature on the crack amendment and the debate over retroactivity.

November 2, 2007 in New USSC crack guidelines and report | Permalink | Comments (5) | TrackBack

November 1, 2007

Some media coverage of new crack guidelines

Here are some of the headlines I have noticed from media stories covering the US Sentencing Commission's now-effective new crack sentencing guidelines:

Of course, these stories provide only the basics of the guideline changes.  For a lot more angles on these issues — including the great retroactivity issue — I have lots of posts in this archive.

November 1, 2007 in New USSC crack guidelines and report | Permalink | Comments (0) | TrackBack

Notable recent coverage of juvenile justice issues

This new AP piece from New York discusses a recent report about juvenile justice in New York and highlights the growing attention being given to these issues lately.  Here are snippets from the AP piece:

New York's juvenile justice system is costly and ineffective, says a statewide coalition that proposed a series of reforms Thursday.  It costs about $150,000 a year to keep a juvenile in a detention center, and yet three out of every four are arrested again within three years of release, according to "Fight Crime: Invest in Kids New York," a nonprofit, anti-crime organization led by more than 300 sheriffs, police chiefs, district attorneys, and victims of violence.

"The state's detention centers are a revolving door," said Skaneateles Police Chief Lloyd Perkins, president of the New York State Chiefs Association. "It's clear that our current system is putting too many juveniles on a path to becoming career criminals. It's expensive, it's not working, and it's time to change."

Too many of the state's most dangerous young offenders are not receiving the intensive interventions needed to address their aggression, substance abuse problems and anti-social behavior, according to the 29-page report titled "Getting Juvenile Justice Right in New York."

In a related vein, NPR has done this set of pieces recently about distinct juvenile justice systems in different states:

November 1, 2007 in Offender Characteristics | Permalink | Comments (1) | TrackBack

NPR segment on race and sentencing issues

I just had the honor and pleasure of doing a live segment on NPR's Talk of the Nation program to discuss race and sentencing issues.  The segment should be available on-line here soon, and this is NPR's teaser:

Recent high-profile cases, such as the case of the 'Jena Six' in Louisiana and Genarlow Wilson's case in Georgia, have brought attention to issues of equality in sentencing.  Guests and callers discuss racial and ethnic disparities in the criminal justice system.

Comments from callers during the program were very informative and insightful, and many rightly stressed that class may be an even more potent factor than race in criminal justices realities.  When I had the mic, I mentioned a number of statistics and recent reports , most of which can be found in these prior posts:

November 1, 2007 in Race, Class, and Gender | Permalink | Comments (0) | TrackBack

Florida Supreme Court upholds state's lethal injection protocol

As detailed in this AP article, Florida's state Supreme Court unanimously ruled today that "Florida's procedure for carrying out execution by lethal injection doesn't conflict with the U.S. Constitution's ban on cruel and unusual punishment."  I suppose what exactly this means in light of Baze will be for others to figure out in the days ahead.

The opinion in Schwab v. Florida can be accessed at this link.

UPDATE:  As a commentator notes, the Court's longer treatment of these issues is in this other opinion, Lightbourne v. McCollum, also released today.

November 1, 2007 in Baze lethal injection case | Permalink | Comments (5) | TrackBack

An arrest is worth a thousand words of legislative testimony

In case anyone wonders how and why state legislators get extra concerned about sex offenders, check out this notable story from my backyard:

What began as testimony on a bill requiring jail sentences for those who solicit sex from minors over the Internet ended in a Statehouse sting for Lt. Jeff Braley of the Warren County Cybercrimes Task Force. 

Though Braley came to Columbus yesterday as a star witness supporting Senate Bill 183, he portrayed himself as a 14-year-old girl on a field trip to the Statehouse in e-mails to Barry Mentser, a local lawyer who police said was trying to have sexual relations with the "girl" he met online. Braley went by the online name "ohiosoccergirl14."  And after Braley testified yesterday, he quickly went to assist Columbus officers in Mentser's arrest....

Braley said he had alerted Columbus police that Mentser likely would be there. Braley said that Mentser had sent him several pictures over the past year -- dressed and undressed -- so State Patrol troopers in the building were able to identify him soon after he entered the building....

Braley said the Statehouse, a busy public building with a host of security cameras and plenty of State Highway Patrol troopers patrolling the halls, is the most public place he's ever made a bust.  "If this guy is going to go to this level, come to the Statehouse where police and everyone are, why would you want him right back out on the street?" he said. "We have to have mandatory jail time for these kind of individuals."  Sen. Tim Schaffer, R-Lancaster, the sponsor of Senate Bill 183, agreed.  "I hope this demonstrates the importance of this issue," he said.

November 1, 2007 in Sex Offender Sentencing | Permalink | Comments (4) | TrackBack

Why all law professors should pay more attention to criminal justice issues

I have such a passion for criminal law issues because so many interesting, dynamic and transcendent philosophical, structural, procedural and practical legal issues arise in the operation of criminal justice systems.  My blogging recently about lethal injection issues (archive here) and about the new crack guidelines (archive here) seeks to reveal some of these issues, but I am really only able to scratch the surface in blog posts.  Relatedly, many of my recent law review articles about the Supreme Court's work in Blakely, and Booker and Rita and other sentencing issues aspire to locate the Court's modern constitutional jurisprudence in broader theoretical and structural contexts.

As I recently suggested here, I am sometimes disappointed and surprised that many high-profile law professor bloggers rarely discuss the transcendent issues that many criminal justice cases implicate.  But today I am pleased to see two thoughtful blog assessments of two cases that show why even seemingly small criminal cases can be so revealing for anyone really interested in legal ideas:

Kudos to Ann and Anita for spotlighting that there is a lot more to learn from and about the Supreme Court's work and the Justices than what a lot of the tired partisan commentary tends to suggest.

UPDATE:  I now see that Orin Kerr has this long new post on Danforth.

November 1, 2007 in Who Sentences? | Permalink | Comments (2) | TrackBack

Wondering once more about the broader impact of a de facto execution moratorium

A few weeks ago I pondered here whether and how a de facto moratorium on executions would impact capital indictments and death sentences.  But that was when the very existence of a moratorium was still subject to robust debate.  Now, as this new USA Today article spotlights, after this week's stay of a Mississippi execution, everyone recognizes the de facto reality of a de facto moratorium:

The Supreme Court's orders in recent death penalty cases have been brief, cryptic and even contradictory.  But after Tuesday night's action stopping a Mississippi prisoner's execution, their consequences seem clear.

Imposition of the death penalty is unlikely to resume until next year, after the justices hear the Kentucky case of Baze v. Rees and rule on the constitutionality of the lethal injections. Most of the 38 states that permit capital punishment use that method.

"The court is sending signals that make it extraordinarily unlikely that there will be any executions before Baze comes out," said Deborah Denno, a law professor at Fordham University in New York. "I think this is unprecedented," added Denno, an expert on lethal-injection issues, referring to the court's decision to review a method of execution for the first time in more than a century and the far-reaching consequences of its orders prior to hearing the case. "It sure looks like that until they decide this issue, they don't want to see any more executions," Georgetown University criminal law professor Randy Barnett said.

So now I wonder again how this moratorium reality is going to impact other aspects of the modern administration of the death penalty.  The USA Today article notes that in "Oklahoma Attorney General Drew Edmonson on Oct. 3 asked state judges not to schedule any executions until the high court rules."  I suspect some other states will take the same approach.  But, the de facto moratorium would be really consequential if state prosecutors and/or judges become less eager to move forward with capital cases.

I am also now wondering about system-wide impacts as well as case-specific ones.  Will the momentum to eliminate the death penalty in a state like New Jersey speed up, or perhaps slow down, in light of the Baze moratorium?  Will some states, as I have wondered recently, start looking at other possible execution methods?  Might Congress, as I urged long ago, finally appreciate that this is an issue of national significance calling for the attention of the nation's legislature?

November 1, 2007 in Baze lethal injection case, Death Penalty Reforms | Permalink | Comments (0) | TrackBack

October 31, 2007

FAMM ready to roll on new crack guidelines

At its website, Families Against Mandatory Minimums has all this new content in conjunction with the effective date for the US Sentencing Commission's new reduced crack guidelines:

10/31/07 - Tomorrow heralds new day for crack cocaine sentencing.  Effective November 1st, nearly 80 percent of defendants convicted of federal crack cocaine offenses will face sentences 16 months shorter on average, thanks to sentencing guideline reforms approved by the U.S. Sentencing Commission.  However, if the amendment is not made retroactive, nearly 20,000 federal prisoners currently serving harsh sentences for crack cocaine offenses will not be eligible for relief. Read more

10/31/07 - Last day to tell the Sentencing Commission to make crack guideline changes retroactive!  October 31 is the last day to write the United States Sentencing Commission in support of making changes to the federal sentencing guidelines for crack cocaine “retroactive."  All letters must be postmarked by Oct. 31.  Click here to write a letter.

10/31/07 - Questions, answers on crack change.  Download answers to requently asked questions about the crack cocaine guideline amendment and possible retroactivity. Click here

Some recent related posts:

October 31, 2007 in New USSC crack guidelines and report | Permalink | Comments (0) | TrackBack

Teague, state powers and retroactivity issues in Danforth

With the recent Wilson ruling from the US Supreme Court and the US Sentencing Commission debating the reach of new crack rules, the issue of retroactivity is coming up again and again.  Today, in a particularly interesting context, the issues was before the Supreme Court in the case of Danforth v. Minnesota.  As previously discussed here, Danforth concerns a state court's authority to apply retroactively Supreme Court criminal procedure rulings and it is a spooky cool case for true law geeks.

Lyle Denniston has this detailed report on the argument, which includes this snippet:

As if conducting an oral exam in basic constitutional law, the Justices explored whether a right that they announce was, in fact, always there though previously undiscovered, or whether it simply emerged as a brand-new product of the judicial imagination. Curiously, some of the Justices who believe that the Constitution means only what it did in the beginning (the “originalist” persuasion) were arguing that the Court certainly can and does creates new constitutional meaning, while some of those who believe in a “living Constitution” (it changes with the times) were suggesting that a new right is simply an old right that always was. It was, for a time, purely “metaphysical,” as Justice Stephen G. Breyer suggested unapologetically. But it could have real-world consequences for individuals accused or convicted of crime.

For those eager to have a first-hand experience with the metaphysical, the transcript of the argument is now available here.  After the goblins have their fun tonight and I get a chance to review the argument, I may have more to say about this interesting case.

October 31, 2007 in Procedure and Proof at Sentencing | Permalink | Comments (0) | TrackBack

First Circuit says Rule 32(h) notice applies to variances

As I noted here a few months ago, the federal circuits have been nearly evenly split on whether FRCrP 32(h) requires a district court to give advance notice before varying from the advisory guidelines range.  Thanks to this post at AL&P, I see that the First Circuit has weighed in today through US v. Vega-Santiago, No. 06-1558 (1st Cir. Oct. 31, 2007) (available here).  Helpfully, this opinion provides this effective account of the state of Rule 32(h) after Booker in the course of articulating the First Circuit's approach:

It appears that only the Seventh Circuit has held that Rule 32 no longer requires notice even for departures, having concluded that, after Booker, "the concept of departures [is] 'obsolete' and 'beside the point.'" United States v. Walker, 447 F.3d 999, 1006 (7th Cir. 2006).  Rule 32(h) remains in effect, however, and the government has in other cases accepted its continuing applicability....

The remaining nine circuits that have thus far addressed the issue have considered whether Rule 32(h) extends to sentencing variances, as well as departures, and they have split five to four.  The Third, Fifth, Eighth and Eleventh circuits hold that the Rule is limited to departures; the Second, Fourth, Sixth, Ninth and Tenth hold that it is not, and have applied the notice requirement to variances as well as departures.  For the reasons we elaborate below, we think the better view is that the notice requirement survives Booker and applies to any non-Guidelines sentence – whether imposed as a departure or as a variance.

October 31, 2007 in Procedure and Proof at Sentencing | Permalink | Comments (12) | TrackBack

Notable state litigation over lethal injection issues

As I noted in this prior post, the Baze case could halt executions for as long as a year if the Supreme Court doesn't issue a ruling until summer 2008, and states thereafter have to figure out exactly what the ruling means for their execution protocols.   Indeed, today brings news that two states with sizeable death rows may be still be facing lots of state litigation after Baze:

As I have suggested before, a state like Texas likely will find a way to get back to executions relatively quickly after a decision in Baze.  But, I would expect de facto moratoriums to persist in some other states for quite a long time.

October 31, 2007 in Baze lethal injection case, Death Penalty Reforms | Permalink | Comments (6) | TrackBack

Wondering about the ripples of the truly consequential crack sentencing news

Though the de facto execution moratorium created by SCOTUS continues to get lots of attention (archive here), the most consequential sentencing news this week actually concerns drug sentencing.  Specifically, as noted here at The BLT, tomorrow the US Sentencing Commission's new reduced crack guidelines become effective.  And though this change will have the biggest impact if the USSC decides to make it retroactive — which could reduce the sentence of 20,000 current federal prisoners — a lot of folks should be impacted by the new crack change right away.

I have heard that a number of crack sentences have been put off while the USSC's proposed amendments were pending.  If this is true, we ought to see a significant up-tick in drug sentencings over the next few months (and a blip in the USSC's drug sentencing data for the last fiscal year).  In addition, there surely are many — perhaps hundreds or even thousands — of crack sentences current on appeal.  I wonder how circuit courts will sort out reasonableness claims and other arguments once the new guidelines become effective.

Last but not least, I wonder if some defendants currently serving time under the old guidelines might bring new appeals even before the USSC decides on retroactivity.  Arguably, the recent Wilson ruling from the Georgia Supreme Court adds heft to claim that sentences under the old guidelines are constitutionally problematic.  Additional support for new constitutional arguments against the old crack sentence might come from commentary like this new Washington Times op-ed from J.C. Watts and Pat Nolan.  Consider these snippets from their piece:

We are both conservative Republicans who are convinced that this country needs a more rational approach to apprehending and prosecuting those who traffic in cocaine.... [The 100-1 sentencing] disparity was passed in 1986 and based largely on the assertion that crack cocaine was more dangerous than powder cocaine, that it was instantly addictive and that it caused violent behavior. Since then, copious scientific evidence and U.S. Sentencing Commission analysis have shown that these assertions, which were not supported by sound data, were exaggerated or even outright false.  The disparity has resulted in a hugely disproportionate number of black Americans sentenced under this mandatory-minimum law.  While the intent was not to single out one racial demographic over another, the impact of these laws amounted to discrimination....

Federal authorities are squandering huge amounts of resources on small cogs in the cocaine distribution network: One-third of all federal cocaine cases involve an average of 52 grams, the weight of a candy bar. This is a terrible misuse of the time and talent of federal law enforcement and prosecutors. Plus, it has clogged the federal courts with cases that can easily be handled by the states.

October 31, 2007 in New USSC crack guidelines and report | Permalink | Comments (3) | TrackBack

Judge complains of federal prosecutors making "illusory" promises in plea agreements

A helpful reader sent me this interesting local story about a federal district judge in Illinois making some interesting statements in the course of recusing himself from an on-going federal criminal case.  Here are the interesting details:

Judge J. Phil Gilbert took the extraordinary step of calling out the U.S. Attorney's Office for the Southern District of Illinois Tuesday before recusing himself from USA vs. Katie R. Heath, a case he said highlights serious problems within the federal prosecutor's office.  "For some prosecutors in the Southern District of Illinois, prosecutions are driven by statistics and a desire to prevent judges from exercising any control over the sentencing process without regard for the individual. Although not rising to the level of mean-spiritedness, the words arbitrary and capricious come to mind," Gilbert said Tuesday during a motion hearing on the case....

Heath was charged in federal court in April 2006 for conspiracy to manufacture, distribute and possess with intent to distribute methamphetamine, conduct related to the previous state prosecution, Gilbert said.  She was set to plead guilty as part of a plea agreement last May, but concerns he had prompted Gilbert to delay the acceptance of the plea and sentencing.  That decision was protested by the U.S. Attorney's office, which filed a motion to reconsider.  The case wound up in the 7th U.S. Court of Appeals, which earlier this month granted a Writ of Mandamus, ordering Gilbert to rule on a motion to reconsider the delay in accepting the plea and sentencing hearing.

Before granting that motion Tuesday, Gilbert said many of his concerns regarding the case involve plea agreements entered into by the prosecution and defendants. "In fact, the government frequently violates plea agreements where the mandatory minimum sentence applies and the defendant's guideline range is substantially below the mandatory minimum," he said.  Gilbert accused the prosecution of making "illusory" promises in the agreements and said, "At least in this district, these so-called plea agreements are one-way streets and are unenforceable at sentencing by either the defendant or the Court."

He went on to say that in Heath's case, where she was already punished by the state for her conduct, "I strongly believe our government has failed here in that they have not been objective, abused their discretion and are not treating (Heath) with a concern for fairness or justice.  In fact, sentencing (Heath) to prison for 20 years would be a miscarriage of justice."... Gilbert said he has never spoken out before, but "I feel strongly that the government has abused their discretion and not treated Katie Heath fairly."

UPDATE:  TalkLeft has more on this story in this post.

October 31, 2007 in Procedure and Proof at Sentencing | Permalink | Comments (4) | TrackBack

Is an execution moratorium scary or sacred or silly or sound?

This piece by Linda Greenhouse at the New York Times notes the import of the Supreme Court's granting of an execution stay in Mississippi last night, calling the stay a "nearly indisputable indication that a majority intends to block all executions until the court decides a lethal injection case from Kentucky next spring."  Here's more:

Even without a written opinion, the Supreme Court’s action on Tuesday night clarified a situation that had become increasingly confusing as state courts and the lower federal courts, without further guidance from the justices, wrestled with claims from a growing number of death-row inmates that their imminent executions should be delayed.  State and lower federal courts are likely to interpret the Supreme Court’s action as a signal that they should postpone executions in their jurisdictions. As a result, the justices will probably not have to consider any more last-minute applications from inmates while the de facto moratorium is in effect.

Especially given that today is a day for spooky festivities — maybe I will dress up as a doctor who refuses to participate in a lethal injection — perhaps readers will share their thoughts about what to make of the suspended state of the death penalty.  Scary, sacred, silly or sound?

Some related posts:

October 31, 2007 in Baze lethal injection case | Permalink | Comments (6) | TrackBack