Dunn v. McNabb
Headline: Ruling lets Alabama proceed with an execution by vacating a lower court’s injunction because the inmate failed to show a significant possibility of success in a challenge to the planned method.
Holding: In granting the State’s application, the Court vacated a district court’s injunction because that court failed to find the inmate had a significant possibility of success in his challenge to the planned method of execution.
- Requires inmates to show a significant chance of success before delaying executions.
- Stops lower courts from blocking executions without required findings.
- Vacates the October 16, 2017 injunction, allowing the scheduled execution to proceed.
Summary
Background
A district court in the Middle District of Alabama entered an injunction on October 16, 2017, blocking a scheduled execution. The State asked a Justice of the Supreme Court to vacate that injunction; the request was presented to Justice Thomas and referred to the full Court, which considered the application.
Reasoning
The Court relied on an earlier rule that inmates seeking time to challenge how a State plans to execute them must meet the usual requirements for a stay, including showing a significant possibility of success on the merits. The Court said the All Writs Act does not let a lower court skip those findings. Because the district court enjoined the execution without finding the inmate had a significant possibility of success, the Court held the lower court abused its discretion and vacated the injunction.
Real world impact
The decision means lower courts must expressly find that an inmate has a significant possibility of winning a challenge before blocking an execution on similar grounds. Practically, the ruling removes the specific injunction entered October 16, 2017, and permits the State to proceed unless other relief is granted. This ruling is a procedural decision about timing and relief, not a final ruling on the underlying merits of the inmate’s challenge.
Dissents or concurrances
Justices Breyer and Sotomayor would have denied the application to vacate the injunction, which indicates they would have left the district court’s blocking order in place.
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