Hamm v. Reeves
The Supreme Court allowed Alabama to proceed with executing Matthew Reeves by lethal injection, overturning orders from two lower courts that had found the state violated federal disability law by failing to help him understand a form offering him the choice of a different execution method.
The unsigned, unexplained order drew a sharp dissent arguing that the Court disregarded careful factual findings by four judges on two courts, and that a short delay would have allowed Alabama to execute Reeves by the less painful method he would have chosen had he been properly informed.
How it got here: A federal district court issued a preliminary injunction blocking Alabama from using lethal injection; the Eleventh Circuit unanimously affirmed; Alabama's corrections commissioner applied to the Supreme Court to vacate the injunction.
The Case in Depth
What happened
Matthew Reeves, a death-row inmate in Alabama, has severe cognitive disabilities and reads at a first-grade level. Alabama gave inmates one month to complete a written form choosing nitrogen hypoxia over lethal injection, but the form required at least an 11th-grade reading level to understand. Reeves sued under the Americans with Disabilities Act, arguing prison officials should have helped him understand the form — and that their failure to do so prevented him from choosing what he believed would be a less painful death.
The question before the Court
Should Alabama be allowed to execute a severely cognitively disabled death-row inmate by lethal injection, even though two lower courts found the state failed to help him understand his right to choose a different execution method?
The Court's answer
Yes — the Court vacated the district court's injunction and allowed Alabama to proceed with the lethal injection execution. The per curiam order provides no written explanation for its decision.
The two lower courts had each found, after extensive briefing and record development, that Reeves was likely to win his disability-law claim and that the balance of harms favored blocking lethal injection — particularly because Alabama could still execute him by nitrogen hypoxia within weeks. The Supreme Court's five-justice majority set those findings aside without explanation.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
For people with cognitive disabilities held in state prisons, this order signals that claims under the Americans with Disabilities Act — which requires government programs to accommodate disabled individuals — may not be enough to pause an execution even when lower courts find substantial merit. It also leaves unresolved how states must handle execution-method choices for inmates with serious reading or comprehension limitations.
What changes now
The Court's order allowed Alabama to proceed with the lethal injection execution on the night of January 27, 2022. Because this is an emergency order and not a final ruling on the merits of Reeves's ADA claim, the underlying lawsuit technically remains pending — though the execution renders the claim for injunctive relief moot. The order does not set binding precedent on whether the ADA requires states to accommodate disabled inmates in choosing execution methods.
What this does not decide
The order does not resolve the merits of whether the ADA requires states to help cognitively disabled death-row inmates understand execution-method election forms. It also does not explain under what circumstances the Court will defer to, or override, lower-court findings in emergency execution cases.
Concurrences and dissents
Dissent — Justice Barrett
Justice Barrett noted, without writing separately, that she would have denied the application — meaning she would have left the lower courts' injunction in place and blocked the lethal injection execution. She did not explain her reasoning.
Dissent — Justice Kagan
Justice Kagan argued that the Court had no basis to override the careful, well-supported findings of four judges on two courts who — after extensive evidence and argument — concluded Reeves's ADA claim was likely to succeed. She stressed that deference to those lower-court findings was legally required, that Reeves would suffer irreparable harm from an execution method he feared and would not have chosen, and that Alabama could still carry out the execution using nitrogen hypoxia within weeks, making the delay trivial compared to the stakes.
How the Court got there
The legal reasoning, step by step
- The legal framework for emergency applications like this one requires the party seeking to undo a lower court's injunction — here, Alabama — to show that the courts below abused their discretion in blocking the execution. The dissent emphasized that this is a demanding standard that normally calls for deference to the judges who built and reviewed the factual record.
- The underlying legal claim rested on the Americans with Disabilities Act (ADA), which requires government programs and services — including, courts have held, state prison programs — to make reasonable accommodations for people with disabilities so they can meaningfully access those programs.
- Reeves's specific argument was that Alabama's process for letting death-row inmates choose their execution method was a covered program under the ADA, and that giving a cognitively disabled inmate who reads at a first-grade level a form written at an 11th-grade reading level — without any assistance — denied him meaningful access to that choice.
- The district court, after reviewing more than 2,000 pages of evidence and seven-plus hours of testimony, found Reeves likely to succeed: his cognitive disability was established, it prevented him from meaningfully accessing the choice process, and his need for help was 'open and obvious' to officials. It granted a preliminary injunction limiting Alabama to nitrogen hypoxia — still allowing the execution to happen, just by the method Reeves would have chosen.
- The Eleventh Circuit unanimously affirmed, finding no abuse of discretion in either the ADA analysis or the weighing of harms. The Supreme Court majority vacated those rulings without issuing any written reasoning, leaving the legal basis for its decision unexplained.