Campbell v. Wood

1994-05-26
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Headline: Court refused to pause or review a scheduled hanging, allowing Washington’s planned execution to proceed while dissenters warned hanging is cruel, risky, and largely abandoned nationwide.

Holding: The Court denied a request to pause a scheduled hanging and refused to review the case, allowing Washington to proceed with the execution while two justices would have blocked it.

Real World Impact:
  • Allows Washington’s scheduled hanging to proceed while review was denied.
  • Leaves the constitutionality of hanging unresolved by the Court.
  • Highlights the risks of decapitation or slow asphyxiation in hangings.
Topics: death penalty, method of execution, cruel and unusual punishment, state execution rules

Summary

Background

Charles Rodman Campbell, a prisoner scheduled to be executed by hanging in Washington, challenged the method as cruel and unusual. The matter came before a Justice and then the full Court; the Court refused to pause the execution and denied review. Justices Stevens and Ginsburg would have granted a pause, and Justice Blackmun issued a written dissent.

Reasoning

The central question was whether execution by hanging violates the Constitution’s ban on cruel and unusual punishment. Justice Blackmun argued that hanging has been abandoned by almost all States, that Washington’s own procedures are based on an old manual and lack trained hangers, and that expert testimony shows serious risks of slow strangulation or decapitation. The Ninth Circuit had upheld hanging unless there was purposeful cruelty, but Blackmun said the risk of torturous outcomes and loss of human dignity make hanging unconstitutional.

Real world impact

Because the Court refused to pause or review the case, Washington’s scheduled hanging may proceed under state law that allows hanging when an inmate does not choose another method. The ruling leaves open the broader constitutional question about hanging and does not settle it on the merits; procedural hurdles and the lack of differing court decisions on the issue could limit immediate nationwide review.

Dissents or concurrances

Justice Blackmun would have granted a pause and review, concluding hanging is cruel and unusual based on evolving standards and widespread state abandonment; Justices Stevens and Ginsburg also favored a pause.

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