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Research on the Argument that Execution Protocol Reform is Biomedical Research, University of Missouri, 2015

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Legal Studies Research Paper Series
Research Paper No. 2015-14

ON THE ARGUMENT THAT EXECUTION PROTOCOL
REFORM IS BIOMEDICAL RESEARCH

Paul Litton
90 WASHINGTON L. REV. ONLINE 87 (2015)

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ON THE ARGUMENT THAT EXECUTION PROTOCOL
REFORM IS BIOMEDICAL RESEARCH

Paul Litton*

INTRODUCTION
The United States Supreme Court just decided Glossip v. Gross,1
rejecting  the  claim  that  Oklahoma’s  lethal  injection  protocol  violates  the  
Eighth   Amendment.   Like   Kentucky’s   protocol   approved   in   Baze v.
Rees,2 Oklahoma’s  procedure  involves  the  administration  of  three  drugs,  
the second and third of which paralyze an inmate and then stop his heart,
respectively. The third drug in both protocols, potassium chloride, would
cause excruciating burning pain if an inmate were not properly
anesthetized, as it flows through his veins. The difference between the
Kentucky protocol permitted in Baze and the Oklahoma procedure
permitted in Glossip is the first drug. Kentucky employed sodium
thiopental,   “a   fast-acting barbiturate sedative that induces a deep,
comalike unconsciousness when given in the amounts used for lethal
injection.”3 Oklahoma’s   first   drug   is   midazolam,   which   is   a  
benzodiazepine, like Valium; it is not a barbiturate. Midazolam is used
primarily   to   relieve   anxiety   and   to   sedate,   not   to   “induce   the   type   of  
deep,   general   anesthesia   needed   to   withstand   painful   stimuli,”4 such as
the burning pain caused by potassium chloride. The pain from the
* R.B. Price Professor of Law, University of Missouri School of Law. Many thanks to Seema Shah
for the opportunity to comment on her excellent article. I am also grateful to the editors of
Washington Law Review for very helpful comments on prior drafts.
1. No. 14-7955, 2015 WL 2473454 (U.S. June 29, 2015).
2. 553 U.S. 35 (2008).
3. Id. at 44.
4. David B. Waisel & Paul Litton, Why the Lethal Injection Drug Debated by the Supreme Court
Today
is
Unconstitutional,
THE
NEW
REPUBLIC
(Apr.
29,
2015),
http://www.newrepublic.com/article/121656/glossip-v-gross-will-determine-constitutionality-lethalinjection.

87

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potassium   chloride   can   “break   through   the   midazolam-induced
sedation,”  causing  the  inmate  to  regain  consciousness.5 Midazolam was
used in at least three executions that have gone terribly wrong over the
last year.6
Condemned inmates in Glossip argued   that   Oklahoma’s   use   of  
Midazolam as the first drug violates the Eighth Amendment because it
creates  a  “substantial  risk  of  serious  harm.”7 According to the plurality
in Baze v. Rees, an execution method is unconstitutional if it presents a
“substantial  risk  of  serious  harm,”  which  is  defined  as  an  “‘objectively  
intolerable  risk  of  harm’  that  prevents  prison  officials  from  pleading  that  
they   were   ‘subjectively   blameless   for   purposes   of   the   Eighth
Amendment.’”8 In addition to arguing that the Oklahoma protocol
presents   a   “substantial   risk   of   serious   harm,”   petitioners   in   Glossip
bolstered their claim that the Oklahoma Department of Corrections is
subjectively blameworthy because of the way in which it chose
midazolam.9 At the preliminary injunction hearing before the federal
district court, former general counsel for the Oklahoma Department of
Corrections  (ODOC)  testified  that  he,  along  with  the  Attorney  General’s  
office, chose midazolam because  “we  knew  [it]  had  the  same  properties  
as  pentobarbital  as  far  as  sedation  goes.”10 The truth is that they did not
know. Pentobarbital, like sodium thiopental, is a barbiturate;
midazolam’s   properties,   in   terms   of   the   kind   of   unconsciousness   it  
causes, are different.11 Accordingly, petitioners in Glossip argued that
the ODOC chose midazolam based on inadequate investigation, lacking
the knowledge required to make a responsible and legally permissible
decision about the execution protocol.12
5. Id.
6. Jason Millman, The Botched Executions Behind the Supreme Court Case on Lethal Injection,
WASHINGTON POST WONKBLOG (Jan. 23, 2015), http://www.washingtonpost.com/blogs/wonkblog/
wp/2015/01/23/the-botched-executions-that-make-people-think-lethal-injection-is-cruel-andunusual/; Ben Crair, 2014 Is Already the Worst Year in the History of Lethal Injection, THE NEW
REPUBLIC (July 24, 2014), http://www.newrepublic.com/article/121656/glossip-v-gross-willdetermine-constitutionality-lethal-injection.
7. Brief of Petitioner at 25, Warner v. Gross, 776 F.3d 721 (10th Cir. 2015) (No. 14–6244), aff’d  
sub nom. Glossip v. Gross, No. 14-7955, 2015 WL 2473454 (U.S. June 29, 2015) (citing Baze v.
Rees, 553 U.S. 35, 50 (2008)).
8. Baze, 553 U.S. at 50 (quoting Farmer v. Brennan, 511 U.S. 825, 846 n.9 (1994)).
9. See Brief of Petitioner, supra note 7, at 11.
10. Transcript of Preliminary Injunction Hearing at 287, Warner v. Gross, 2014 WL 7671680
(W.D. Okla. Dec. 22, 2014) (No. CIV-14-665-F), available at https://www.law.berkeley.edu/clinics/
dpclinic/LethalInjection/LI/Glossip/documents/2014-12-17WARNER1(RT)(FINAL).pdf.
11. Brief of Petitioner, supra note 7, at 2–3 (citing Baze, 553 U.S. at 50).
12. Id. at 10–11.

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Regardless of whether the Supreme Court rightly decided Glossip,
Oklahoma officials had inadequate reason to choose midazolam as the
first drug. Its decision to try midazolam is one example illustrating
Seema   Shah’s   point   that   death   penalty   states,   in   using   new   drugs   and  
drug   combinations,   are   engaged   in   “poorly   designed   experimentation  
that  is  not  based  on  evidence.”13 Shah  argues  that  “an  important  factor”  
causing the high rate of botched executions is that the lethal injection
reform in which states are engaged is a type of human subjects research
that is going unregulated.14
Shah’s   arguments   in   Experimental Execution are creative and
thought-provoking. Their importance resides in the fact that all possible
legal avenues should be identified and explored for prohibiting reckless
choices by departments of corrections in their design of execution
protocols.   Shah’s   work,   appealing   to   ethical   and   legal   principles  
governing human subjects research, is one such worthy exploration. Her
claim that recent reforms constitute research has strong intuitive appeal.
As she writes:
All states conducting executions . . . borrow and learn from one
another’s   experiences   and   tend   to   change   their   protocols   by  
adopting the same new drugs around the same time. This
suggests that states are making modifications and experimenting
with the goal of producing knowledge from each individual
execution to improve future executions.15
As evidence of the value of her exploration into the application of
research ethics and law, we see attorneys for death row inmates urging
courts to consider recent lethal injection reforms as unnecessarily risky
human subjects research. The plaintiffs in Glossip, for example, argued
that   the   “State’s   hasty,   ill-founded, non-medical approach to the
selection of midazolam as an execution drug, does not accord with basic
expectations  of  research.”16
Part  I  of  this  essay  grants  Shah’s  conclusion  that  death  penalty  states  
are engaged in human subjects research. However, it argues that if
protocol reform amounts to research, then it is unethical for lacking
social value, regardless of the morality of capital punishment. Shah
argues that research ethical requirements, such as informed consent and
Institutional Review Board (IRB) review, are necessary to render the
13. Seema K. Shah, Experimental Execution, 90 WASH. L. REV. 147, 147 (2015).
14. Id.
15. Id. at 182.
16. Brief of Appellant at 13, Warner v. Gross, 776 F.3d 721 (2015), aff’d   sub  nom. Glossip v.
Gross, No. 14-7955, 2015 WL 2473454 (U.S. June 29, 2015) (No. 14–6244).

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research ethically permissible. I argue that we need not get that far if it is
research: Because it lacks social value, it is unethical.
Parts II and III provide reasons to doubt the empirical claims and
normative conclusions of Experimental Execution.   Shah’s   normative  
conclusion is that the law and ethics of human subjects research should
govern lethal injection reform. Empirical claims underlie that normative
view.   Shah   argues   that   the   capital   inmate’s   relationship   to   the  
corrections department is sufficiently similar to the relationship between
a research participant and investigator. She also claims that the
application of the law and ethics of human subjects research will help
ensure   less   suffering   during   executions.   Part   II   argues   against   Shah’s  
normative conclusion by providing reasons to reject its underlying
empirical assumptions. Finally, Part III argues that describing lethal
injection reforms as human subjects research fails to add moral or legal
reasons to condemn the way in which states have conducted recent
executions.
I.

IF IT IS RESEARCH, DOES IT HAVE SOCIAL VALUE?

If Shah is correct that states are engaging in medical research, then
this research is unethical. Of course, one might argue that the research is
unethical because the death penalty is immoral. However, I contend that
even if the death penalty is a morally permissible punishment in at least
some cases, this alleged research would be unethical for the state to
conduct because it fails the research ethics requirement of providing new
and valuable knowledge. In other words, I argue that even if the death
penalty   is   morally   permissible,   the   “research”   nonetheless   lacks   social  
value.   Even   if   states   adopted   Shah’s   recommendations   of   requiring  
informed consent and IRB review, the research would still be unethical.
To start, a research protocol is ethical only if that research has social
value.17 When   research   seeks   to   find   “what   is   already   well   known”   it  
lacks social value.18 It is ethically impermissible to expose persons to
medical risks—especially persons who are particularly vulnerable to
coercion—if the research lacks social value.19
Regardless of whether the death penalty is morally justifiable, the

17. Ezekiel Emanuel et al., Research Ethics: How to Treat People Who Participate in Research,
NATL. INST. OF HEALTH 4 (2011), available at http://www.bioethics.nih.gov/education/pdf/
FNIH_BioethicsBrochure_WEB.PDF.
18. Id.
19. See Ezekiel Emanuel et al., What Makes Clinical Research Ethical?, 283 JAMA 2701, 2703
(2000).

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“experimenting”   in   which   states   are   engaged   lacks   social   value.   Shah  
asserts that the aim   of   the   experimentation   is   to   “improve   [execution]  
protocols  to  use  on  other  inmates  on  death  row.”20 In what way are states
trying  to  “improve”  their  protocols?  I  do  not  want  to  attribute  an  answer  
to Shah, but one intuitive answer is the following: States are trying to
find a lethal injection procedure that will terminate a life while
minimizing the risk of pain and suffering. The problem, though, is that
this cannot be the actual aim of the experimentation: We already know
how to kill someone without causing suffering. Physicians perform
neurosurgery, and patients feel nothing. Some states use a single
overdose of a barbiturate, the same kind of drug that has been prescribed
in Oregon under its Death with Dignity Act.21 And even if states cannot
obtain a barbiturate for single-dose executions, other means of killing
quickly, minimizing the risk of prolonged suffering, exist. Surely people
know that the state can render an inmate unconscious with some drug—
whether it is a drug used by medical professionals or not—and then kill
him by means that governments have used in the past. The state could
intoxicate and anesthetize an inmate and then riddle his head with
bullets, blowing up his brain and causing death in an instant. The state
could render an inmate unconscious before employing the guillotine. I
am sure others can think of many more such execution protocols that
would kill an inmate quickly right after rendering him unconsciousness.
Consider  the  following:  The  reason  midazolam’s  use  in  executions  is  so  
problematic is because potassium chloride does not kill instantaneously.
The  searing  pain  it  causes  is  “sufficiently  noxious  to  break  through  the  
midazolam-induced  sedation.”22 If the burning pain causes the inmate to
regain consciousness, there is time for him to suffer intensely. Death
might take up to two minutes.23 Midazolam would not be a problem in
terms of permitting pain if, after it causes unconsciousness, the inmate
were killed instantly.
So  what  is  the  supposed  aim  or  value  of  this  “experimentation”  if  it  is  
not to find a way to kill someone while minimizing the risk of pain?
20. Shah, supra note 13, at 152.
21.State by State Lethal Injection, DEATH PENALTY INFORMATION CENTER,
http://www.deathpenaltyinfo.org/state-lethal-injection (last visited June 29, 2015) (listing states
using pentobarbital in a one-drug protocol); OR. DEP’T OF HUMAN SERVS., SIXTH ANNUAL REPORT
ON
OREGON’S
DEATH
WITH
DIGNITY
ACT
23
(2004),
available
at
https://public.health.oregon.gov/ProviderPartnerResources/EvaluationResearch/DeathwithDignityA
ct/Documents/year6.pdf.
22. Waisel & Litton, supra note 4.
23. Mark Dershwitz & Thomas K. Henthorn, The Pharmacokinetics and Pharmacodynamics of
Thiopental as Used in Lethal Injection, 35 FORDHAM URB. L. J. 931, 946 (2008).

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Perhaps other options for killing painlessly that I mentioned (besides a
barbiturate overdose) are more gruesome, and inmates themselves have
an interest against such executions even if painless. I am skeptical,
though, that pro-death-penalty states are motivated by a concern to
protect dignity interests of condemned inmates for the sake of the
inmates.
Rather, I suggest the following: Death penalty states want to
terminate an inmate’s  life  using  only  drugs  because  doing  so  makes  the  
death penalty more palatable to others, including the public. As others
have   observed,   “[l]ethal   injection   looks   more   like   therapy   than  
punishment.”24 The   purpose   of   killing   with   drugs   is   to   “mask   the
brutality of execution by making them look serene and peaceful—like
something   any   one   of   us   might   experience   in   our   final   moments.”25
Some commentators surmise that the level of public support for the
death   penalty   rests   in   part   on   the   “medicalization”   of executions.26 By
medicalizing executions, the state can maintain and influence public
support for the death penalty.
If the state conducts human subjects research to find a means of
killing that permits the state to maintain and influence public support for
the death penalty, then that research is immoral. The state disrespects the
public by attempting to influence public opinion by a means that has
nothing to do with the reasons to support the death penalty.
Medicalizing executions may cause people to feel more comfortable
with killing; it avoids causing feelings of disgust and horror that might
be caused by more graphic newspaper accounts of executions by other
means. However, the fact that executions are medicalized and sanitized
neither constitutes nor reveals any reasons that morally speak in favor of
capital punishment. It is illegitimate for the state to try to influence
public opinion in a way that bypasses reasoning.
The state may attempt to maintain or influence public opinion on an
important social matter such as the death penalty. The government may
“defend  its  own  policies.”27 However, in a democracy, the state may not
24. Deborah W. Denno, When Legislators Delegate Death: The Troubling Paradox Behind State
Uses of Electrocution and Lethal Injection and What It Says About Us, 63 OHIO ST. L.J. 63 (2002)
(quoting Jerome D. Gorman et al., The Case Against Lethal Injection, 115 VA. MED. 576, 576–77
(1988)).
25. Wood v. Ryan, 759 F.3d 1076, 1103 (9th Cir. 2014) (Kozinski, J., dissenting from denial of
rehearing en banc).
26. See, e.g., Daniel N. Lerman, Second Opinion: Inconsistent Deference to Medical Ethics in
Death Penalty Jurisprudence, 95 GEO. L.J. 1941, 1947 (2007).
27. Bd. of Regents of the Univ. of Wisconsin Sys. v. Southworth,  529  U.S.  217,  229  (2000)  (“The  
government, as a general rule, may support valid programs and policies by taxes or other exactions

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try to influence public opinion on an important matter in a way that
bypasses   “reasoned   discussion   and   deliberation.”28 Whether legislators
and citizens support or oppose the death penalty should be based on
questions about its retributive value (if any), its deterrent value (if any),
and other moral, policy, and financial considerations. It is morally
illegitimate for the state to manipulate public opinion by means that have
nothing to do with reasons that speak for or against capital punishment.
Therefore, if Shah is correct in deeming lethal injection reform to be
human subjects research, then the research fails the requirements for
ethical research regardless of any consent process or expert review.
II.

ARE RESEARCH ETHICS REQUIREMENTS APPLICABLE?

Shah  is  certainly  right  that  the  “mere  fact  that  an  inmate  is  sentenced  
to death should not suspend the standard protections to which all of us
are   entitled.”29 The question, though, is whether good reason exists to
apply the law and ethics of research to the lethal injection context. If
good reason is lacking, then we are not suspending research protections
to which an inmate is entitled. In this section I argue that good reason
does not exist to apply research ethics requirements to lethal injection
reform. The relationship between condemned inmates and corrections
departments (including the execution team) is not similar for ethical
purposes to the relationship between research participants and
investigators. Second, the justifications for particular research ethics
requirements—such as informed consent—are inapplicable in the lethal
injection context.
The  essence  of  Shah’s  normative  argument that the law and ethics of
research should bind execution reform is the following: There are
features of research that call for strong ethical and legal requirements,
and those same features also exist in the execution context. First,
research may involve risks of bodily harm to research subjects.
Similarly, experimentation with lethal injection protocols involves risks
of suffering to condemned inmates. Second, research necessarily
binding on protesting parties. Within this broader principle it seems inevitable that funds raised by
the government will be spent for speech and other expression to advocate and defend its own
policies.”).  My  argument  does  not  dispute  the  government  speech  doctrine,  according  to  which  the  
state may express its own point of view even on morally contentious issues. Id.
28. Tom
Christiano,
Democracy,
STAN.
ENCYCLOPEDIA
PHIL.,
http://plato.stanford.edu/entries/democracy/   (discussing   Joshua   Cohen’s   account   of   democracy  
described in Procedure and Substance in Deliberative Democracy, in PHILOSOPHY AND
DEMOCRACY 21 (Tom Christiano ed., 2002)).
29. Shah, supra note 13, at 155.

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involves parties—researchers and patient-subjects—who have diverging
interests. Researchers want to produce generalizable knowledge that
may lead to the improvement of human welfare. They may also seek
personal   benefit   from   their   work   and   publications,   including   “prestige,  
status, career advancement, satisfaction of curiosity, and   money.”30
Patient-subjects, though, are the ones who face the risks required for
researchers to achieve their goals. Likewise, Shah argues, the interest of
a corrections department and an inmate are not perfectly aligned.31 Both
have an interest in a painless execution, but the corrections department,
lacking certainty about drug effects, has an interest in producing
knowledge for future executions. Perhaps, though, an even more
worrisome concern is that corrections departments deal with political
and time pressure to change an execution method because of drug
shortages or other reasons.
Shah is right that these diverging interests are cause for concern. The
recent Oklahoma experience demonstrates how time and political
pressure on a corrections department can lead to a terrible choice of
drug.32 However, the fact that condemned inmates may suffer harm and
have interests in tension with corrections officials does not imply that
the same ethical and legal requirements should bind the execution
context.
For example, consider the informed consent requirement for medical
research. Shah argues that extending the ethical requirement of informed
consent to condemned inmates can or will help reduce the risks of
unnecessary suffering that they face. In human subjects research, the
ethical   requirement   of   informed   consent   has   two   purposes:   “to   ensure  
that individuals control whether or not they enroll in clinical research
and participate only when the research is consistent with their values,
interests, and preferences.”33 Shah   argues   that   “just   as   some   inmates  
might be given a choice to participate in research . . . testing a new
medication for treating HIV, so too should inmates be asked for their
consent to participate in research about   how   they   should   be   killed.”34
Moreover, Shah argues that requiring informed consent before enrolling
an inmate in execution research will actually help the inmate protect his
interests.35 For example, Shah argues, an inmate with a particular
30.
31.
32.
33.
34.
35.

Id. at 164.
Id.
Brief of Appellant, supra note 16, at 22–27.
Emanuel, supra note 19, at 2706.
Shah, supra note 13, at 199 (emphasis in original).
See id. at 198–202.

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medical condition that increases the risk of a painful lethal injection
might be able to bring his condition to bear in a decision about whether
to  participate  in  the  state’s  protocol  reform  efforts.36
Shah’s   empirical   assumption   is   that   asking   death   row   inmates   to  
consent to execution research will help them protect their interests.
However, if that empirical assumption is false, then the normative
conclusion—that the informed consent requirement should be applied—
loses its justification. In the following, I explain why I am skeptical of
the empirical assumption.
First, I must admit finding something morally grotesque about the
state asking an inmate, who the state is about to kill, for permission to
expose the inmate to risk so that it may find the best way to kill others in
the future. It is hard to imagine why an inmate would or should be
disposed to helping the state in this manner. Let us first contrast an
execution with the normal medical context in which a physician or
researcher asks a patient to enroll in research. It is reasonable for a
physician to ask a patient if she is willing to participate in research and
bear risk for the good of others because perfectly intelligible reasons
exist  to  justify  a  patient’s  agreement.  For  one,  some  patients  consent  to  
research for altruistic reasons; they want to contribute to improving
human welfare. Patients can derive meaning from their illness by
participating in research that will hopefully help prevent or alleviate the
suffering of people in the future.37 A patient might also reasonably
believe that she has benefitted greatly from the advancement of medicine
and therefore has a responsibility to participate in the ongoing
production of medical knowledge. In addition, patients often feel good
will towards their doctors, grateful for the way in which their doctors
have cared for them. The context makes it quite understandable why a
patient would see good reason to accept an invitation to enroll in
research and take on risk for the good of others. Accordingly, some
commentators have described the ideal researcher-subject relationship as
a joint venture, in which they share in the goal of improving human
welfare.38
These facts do not apply to the execution context. Execution
“research”  cannot  be  a  joint  venture.  A  condemned  inmate  does  not  have  
reason to be altruistic towards the state, which is killing him against his
36. Id. at 200.
37. Paul Litton & Franklin G. Miller, A Normative Justification for Distinguishing the Ethics of
Clinical Research from the Ethics of Medical Care, 33 J.L. MED. & ETHICS 566, 569 (2005).
38. See, e.g., CHARLES FRIED, MEDICAL EXPERIMENTATION: PERSONAL INTEGRITY AND SOCIAL
POLICY 172 (1974).

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will, to help the state find a way to execute that sits well with the public.
Again, as argued before, the state knows how to kill people quickly with
little risk of pain. The purpose of this alleged research is to find ways to
kill that maintain support for the death penalty. We should hope that
guilty inmates attempt to repent, reform, and benefit others in ways they
can. However, we should not expect that their rehabilitation include
volunteering for  the  state’s  endeavor  to  find  a  more  peaceful  way  to  kill  
more inmates. A patient might see an obligation to help advance
medicine because of the medical benefits she has received throughout
her life. Inmates have no analogous obligation to the state to help it
maintain the death penalty; they have not received benefits from the
existence of the death penalty. Finally, unlike the normal good will
within the doctor-patient relationship, the execution differs in that
inmates most often lack good will towards the state. It is just unseemly
of the state, before killing a person, to ask him to take on risk so that it
can kill others.
Shah also supports her conclusion—that ethical and legal
requirements of research should apply to execution reform—by claiming
that the application of those requirements, such as informed consent, will
help inmates protect their own interests and reduce their risk of
suffering.39 However, it is difficult to see how an informed consent
requirement will help an inmate protect his interests. The context is
plainly coercive. Corrections officials, asking the inmate to consent, are
in control of whether he is going to suffer extreme pain during the
execution. They are going to kill him one way or another. The inmate
wants to make sure that the risk of pain is as low as possible. He is not
sufficiently free to decline when he knows that agents acting on behalf
of corrections are in control of whether he suffers or not. Executioners
can deliberately cause pain, and whether or not they would, an inmate
may certainly and legitimately fear such intentional infliction of pain.
Consent may be informed, but, for ethical purposes, it would not be
freely given.
Another obstacle to meaningful informed consent is the fact that both
options—the   “standard”   or   “unmodified”   protocol,   and   the  
“experimental”   or   “modified”   protocol—might be terrible. To use
Shah’s   words,   both can   be   “poorly   designed   and   not   based   on  
evidence.”40 A non-lethal injection option might even be barbaric. Shah
writes:   “States   seeking   to  modify   their   lethal  injection   protocols   would  
39. Shah, supra note 13, at 198–202.
40. Id. at 155.

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have to ask inmates whether they prefer the modified or unmodified
version of the protocol or could offer inmates a choice of a different
method   of   execution   altogether.”41 That choice, according to Shah,
might   involve   “older   methods   of   execution   to   offer   alternatives.”42
Imagine the choice is between lethal gas—an older method of
execution43—and some experimental lethal injection protocol that, say,
uses midazolam as the first drug. The inmate choosing the latter is not
freely giving informed consent to participate in research for the good of
others. That inmate could very well choose the experimental method
because of the known horrors of dying via lethal gas.44 In medical
research, usually one option for a patient is the standard of care, the best
treatment we have, given current knowledge. Given the way states have
concocted their execution protocols, there is no reason to trust that the
“unmodified,”   non-experimental option for execution is actually
acceptable and constitutional.
The objections I have raised so far cast doubt on whether an informed
consent requirement would allow inmates to actually protect their own
interests and reduce the risk of a botched, painful execution. There is
another obstacle, not to the inmate protecting himself, but to
implementing such a requirement. Who would actually administer the
informed consent process and how would it be done? The process should
not be administered by a department of corrections employee who is not
a medical professional. Informed consent is not merely about obtaining a
research   participant’s   agreement;;   it   is   supposed   to   be   a   process   of  
communication in which the potential participant learns about the nature
and purpose of the research, the risks and benefits of enrolling, and the
risks and benefits of alternatives to participation.45 The potential
participant should also have the opportunity to ask questions so that her
decision may be fully informed. The federal regulations, for example,
require   the   informed   consent   process   to   include   “[a]n   explanation   of  
whom  to  contact  for  answer  to  pertinent  questions  about  the  research.”46
Non-medical professionals cannot be the only willing administrators of
41. Id. at 199.
42. Id. at 200.
43. MO. REV. STAT. § 546.720  (2014).  (“The  manner  of  inflicting  the  punishment  of  death  shall  
be  by  the  administration  of  lethal  gas  or  by  means  of  the  administration  of  lethal  injection.”).
44. See Deborah W. Denno, The Lethal Injection Quandary: How Medicine Has Dismantled the
Death Penalty, 76 FORDHAM L. REV. 49,  63  (2007)  (discussing  Donald  Harding’s  horrific  execution  
by lethal gas in Arizona).
45. Emanuel, supra note 19, at 2706.
46. 45 C.F.R. § 46.116(a)(7) (2014).

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this process. At least one medical professional must be on hand to
answer questions about this alleged research.
But would—and should—any physician actually participate in this
manner in an execution? Professional medical societies, such as the
American Medical Association (AMA), American Society of
Anesthesiologists, and the American Nurses Association, condemn the
participation of medical professionals in executions. The AMA Code of
Ethics specifically condemns even consulting the execution team, which
a physician who administers an informed consent process would have to
do. This consensus among professional organizations is why some
states, such as California,47 have been unable to secure participation of
physicians in their executions. Granted, some other jurisdictions have
been able to employ physicians for executions.48 However, would it be
ethical for a physician to steward a condemned inmate through the
informed consent process for purposes of enrolling him in execution
research? Some commentators have defended physicians who participate
in executions.49 Are their arguments applicable to the current issue at
hand?
Though commentators have presented reasonable arguments
defending the participation of physicians in some execution procedures,
their arguments would not support physician administration of an
informed consent process. These commentators have challenged the
ethics position of the AMA and other professional organizations by
arguing that physicians can actually reduce the risk of unnecessary
suffering during an execution.50 A traditional function of medicine is to
reduce the risk of suffering. Insofar as a physician can ensure proper
delivery of a barbiturate, which would prevent excruciating pain that
would otherwise be caused, a physician acts in accordance with
principles of medical ethics. These arguments in favor of physician
participation,   though,   cannot  justify   a   physician’s   administration   of  the  
informed consent process through which a death row inmate is asked to
participate  in  “execution  research.”  If  my  concerns  above  are  correct,  an
informed consent requirement will not effectively permit inmates to
protect their own interests. As stated, the context is necessarily coercive.
A   physician   might   be   able   to   protect   an   inmate’s   interest   by   ensuring  
47. Denno, supra note 44, at 49.
48. Atul Gawande, When Law and Ethics Collide: Why Physicians Participate in Executions, 354
NEW ENG. J. MED. 1221, 1223 (2006).
49. See, e.g., David Waisel, Physician Participation in Capital Punishment, 82 MAYO CLIN.
PROC. 1073 (2007).
50. Id.

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proper delivery of the barbiturate, to make sure the inmate does not
experience any suffering. However, if the execution is truly research to
produce generalizable knowledge for future state-sanctioned killings, it
is   difficult   to   see   how   a   physician’s   administration   of   an   alleged  
informed consent  process  could  really  protect  an  inmate’s  interests.
III. DOES  CALLING  IT  “RESEARCH”  MATTER?
Shah rightfully asserts that the lethal injection reforms implemented
by  states  are  “poorly  designed  and  not  based  in  evidence.”51 Their poor
design and lack of evidentiary support are, according to Shah, causing
the disturbing rate of botched executions. Shah aims to address the root
of  the  problem:  “Viewing  lethal  injection  executions  through  [the  lens  of  
research ethics] can help ensure that states have a solid scientific basis
and are neither excessively risky nor disrespectful of inmates on death
row.”52
Is  the  ethical  problem  that  the  protocols  are  “poorly  designed  and  not  
based   in   evidence,”53 or   that   they   are   “poorly   designed   research”54
inadequately supported by evidence? By calling these reforms
“research,”   would   we   add  either   to  the   moral   or  legal   reasons  the   state  
has  to  avoid  execution  methods  that  are  “poorly  designed  and  not  based  
on  evidence”?  In  this  section  I  argue  that  we  would  not.
To begin, the state already has an extremely strong moral obligation
to respect condemned prisoners as persons, regardless of their crimes; it
is immoral to choose methods of punishment that are poorly designed.
Even worse, it is, at the least, grossly negligent to choose a method of
execution that supposedly involves administering an effective anesthetic
agent when there is good scientific reason to doubt that the chosen
means of anesthesia does not actually have the desired medical
properties.
The   state’s   moral   obligation is based on the fact that it is inflicting
punishment. Given the extreme harm the state inflicts on a prisoner, the
state  is  morally  justified  only  if  “the  end  to  be  achieved  is  of  undeniable  
importance to society, and no less severe [punishment] will suffice.”55
51.
52.
53.
54.
55.

Shah, supra note 13, at 152.
Id. at 153.
Id. at 152.
Id. at 191 (emphasis added).
Hugo Adam Bedau, An   Abolitionist’s   Survey   of   the   Death   Penalty   in   America   Today, in
DEBATING THE DEATH PENALTY: SHOULD AMERICA HAVE CAPITAL PUNISHMENT? 32 (Hugo A.
Bedau & Paul G. Cassell eds., 2004).

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The fact that punishment is morally justified only if it is necessary to
achieve a compelling state interest—only if a less severe punishment is
not adequate—is why the Supreme Court, in its death penalty
proportionality cases, asks whether the challenged punishment serves a
legitimate state purpose such as retributive justice or deterrence.56 If a
punishment is not needed to serve a state interest, it is unjustified. The
infliction of severe suffering without justification is, indeed, cruel.
Correspondingly, the state has a moral obligation to inflict punishment
only when necessary. If state officials, by poorly designing a protocol
without a scientific basis, culpably inflict torturous suffering upon an
inmate that exceeds what is necessary to inflict his sentence, then such
officials have grossly violated a serious moral obligation owed to
affected inmates.
Categorizing   the   lethal   injection   reform   as   “research”   just   does   not  
add to our moral reasons to condemn the state for using execution
methods  so  hastily  and  unjustifiably  chosen.  Shah’s  position  reminds  me  
of  Joseph  Raz’s  question  of  whether  a  moral  obligation to obey law adds
to   an   individual’s   moral   reasons   to   refrain   from   committing   murder   or  
other violent crime.57 The fact that the law punishes such crimes
provides self-interested reasons to refrain; but does the law add to our
moral obligation to refrain? Given the weight of our moral obligation to
refrain from committing murder, any alleged moral obligation to obey
the law adds no weight to our moral obligation to refrain from
violence.58 Analogous to the present context, the question is whether
calling the  changes  to  lethal  injection  protocols  “research”  adds  anything  
to   the   state’s   moral   obligations   to   avoid   “poorly   designed”   execution  
procedures  that  are  not  based  on  science.  Given  the  weight  of  the  state’s  
obligation to avoid the infliction of unnecessary suffering through poorly
designed punishment, an alleged duty to avoid poorly designed research
adds  very  little  to  the  state’s  moral  obligations  in  this  context.    
Shah contends, though, that the law governing research is also
applicable, in addition to research ethics.59 The law of research, like
research ethics, requires risk minimization.60 Shah argues that the
56. See, e.g., Kennedy v. Louisiana, 554 U.S. 407 (2008); Roper v. Simmons, 543 U.S. 551
(2005); Atkins v. Virginia, 536 U.S. 304 (2002).
57. See Joseph Raz, The Obligation To Obey: Revision and Tradition, 1 NOTRE DAME J.L.
ETHICS & PUB. POL’Y 139 (1984).
58. Id. at 140–41.
59. Shah, supra note 13 at 157.
60. See, e.g., 45  C.F.R.  §  46.111(a)  (2014)  (“In  order  to  approve  research  covered  by  this  policy  
the IRB shall determine that . . . (1) [r]isks to subjects are minimized . . . .”).

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Court’s   Eighth   Amendment   jurisprudence   is   not   as   protective   as  
regulations   that   govern   research.   Chief   Justice   Roberts’s   plurality  
opinion in Baze does not require risk minimization. An execution
protocol can fail to minimize risks yet, simultaneously, pass Baze’s  
standard   by   presenting   less   than   a   “substantial   risk   of   serious   harm.” 61
Shah   argues,   “Justice   Ginsburg’s   dissent   requiring   that   there be no
‘untoward   risk’   was   the   only   standard   that   was   consistent   with   the  
obligation  to  minimize  risks  in  research  or  quality  control  activities.”62
Is   there   a   practical   difference   among   a   prohibition   on   “substantial  
risk[s]   of   serious   harm,”   a   prohibition   on   “untoward   risk[s],”   and   a  
requirement that risks be minimized? On their face, I agree with Shah
that they differ. On the other hand, we have reason to wonder whether,
or  how  often,  a  decisionmaker  disposed  to  seeing  an  “untoward”  risk  of  
harm would deny   the   existence  of  a   “substantial   risk   of   serious   harm,”  
particularly in the execution context. In attempts to apply these
standards, how often would the same decisionmaker conclude that an
execution protocol fails to minimize risks yet simultaneously find no
substantial risk of serious harm? The same decisionmaker might be
prone  to  seeing  a  “substantial  risk  of  serious  harm”  in  the  same  case  she  
concludes that the state has failed to minimize the risks involved in an
execution.
In  fact,  consider  Shah’s  own application of the Baze plurality standard
in the following passage. It suggests that Shah sees current lethal
injection experimentation as not only failing the research requirement to
minimize risk, but also as violating the more permissive standard from
the Baze plurality:
Importantly, the plurality opinion in Baze indicated that a lethal
injection protocol would violate the Eighth Amendment if it
involves  a  “substantial  risk  of  serious  harm”  or  an   “objectively
intolerable   risk   of   harm,”   and   there   are   alternative execution
methods   that   effectively   address   this   risk.”   When   faced   with  
examples   of   problematic   executions,   the   Court   opined   that   “an  
isolated   mishap,”   or   an   “accident, with no suggestion of
malevolence” would not be enough to sustain a challenge based
on the Eighth Amendment. Yet, states are increasingly engaged
in experimentation that disregards many potential risks and the
considerable uncertainty as to whether procedures will work as
planned. Given the growing number of examples of executions
gone wrong, it is difficult to believe that these failures are
61. Baze v. Rees, 553 U.S. 35, 52 (2008).
62. Shah, supra note 13, at 196. (citing Baze, 553 U.S. at 123 (Ginsburg, J., dissenting)).

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merely a series of accidents. Rather, the problem is systemic and
foreseeable. Poorly regulated and haphazard experimentation on
inmates predictably leads to bad outcomes.63
“Given  the  growing  number  of  examples  of  executions  gone  wrong,”  we  
should   not   view   the   terrible   outcomes   as   “isolated   mishap[s]”   or  
“accident[s],   with   no   suggestion   of   malevolence.”   Perhaps   the  
malevolence is not equated with purposeful infliction of suffering, but
recklessness and indifference can be malevolent, particularly in this
context.
Finally, if the Baze standard  is  not  strong  enough  to  prohibit  “poorly  
designed”   protocols   that   are   “not   based   on   evidence,”   then   there   is   a  
problem with the Baze standard. There is no justification for the state to
execute death row inmates with recklessly chosen procedures. Reckless
or grossly negligent infliction of torturous suffering has no justification,
and, as such, is cruel. States have a constitutional obligation to avoid
cruel and unusual punishments. The Constitution already forbids the
reckless and grossly negligent infliction of torturous suffering, whether it
is inflicted through means that look like medical research or not.
Therefore, labeling recent reforms  as  “research”  seems  to  add  little  to  the  
state’s  legal  reasons  to  avoid  “poorly  designed”  protocols  “not  based  on  
evidence.”
CONCLUSION
Shah’s  goal  is  admirable.  Finding  recent  reforms  to  count  as  research,  
she argues that some kind of independent oversight is required to
prevent states from employing poorly designed execution methods in
their quest to kill the very few offenders who are sentenced to death. As
explained, I am not persuaded that her creative suggestion is the
solution. The relationship between death row inmates and corrections
officials is not analogous, from an ethical perspective, to the research
subject-investigator relationship. Moreover, the legal and ethics
requirement of informed consent for research will not help inmates
protect their interests. These two facts are reasons why the law and
ethics of human subjects research is not applicable to lethal injection
reform. Nonetheless, states have weighty ethical and legal obligations to
cease employing poor means of execution. Terribly designed protocols
have no justification.
Shah and I join the call for rationality in the search for a humane

63. Id. at 153 (emphasis added) (citations omitted).

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method of killing. I do, however, readily admit that such a call is,
perhaps, hopeless and odd. Death penalty states seem unwilling even to
assess whether having capital punishment is rational. In my own state of
Missouri, a senate committee annually refuses to bring to the floor a bill
that would simply require the state auditor to calculate the financial cost
of the death penalty to the state.64 Politicians do not want to know
whether there are any reasons to abolish the death penalty. Hopefully
recent botched executions will cause states not only to reexamine their
protocols, but to have the courage to assess whether this punishment,
which constitutes such a small part of the criminal justice system, is
actually worth its trouble and cost.

64. Press Release: Sen. Keaveny Files Legislation Examining Coasts of Administering Death
Penalty
in
Missouri,
THE
MISSOURI
TIMES
BLOG
(Jan.
14,
2015),
http://themissouritimes.com/15885/press-release-sen-keaveny-files-legislation-examining-costsadministering-death-penalty-missouri/. The most recent bill did not pass out of the Governmental
Accountability and Fiscal Oversight Committee despite bipartisan sponsorship. MO SB240,
BILLTRACK50, https://www.billtrack50.com/BillDetail/543125 (last visited June 29, 2015).