Supreme Court of the United States

Nelson v. Campbell

May 24, 2004541 U.S. 637

Summary

Justice O’Connor delivered the unanimous opinion holding that Nelson could use § 1983 to challenge the proposed cut-down procedure for obtaining venous access before lethal injection. On the complaint’s allegations, the procedure was unnecessary, acceptable alternatives existed, and success would not necessarily prevent Alabama from executing him. The Court did not decide how method-of-execution challenges generally should be classified or whether the cut-down procedure violated the Eighth Amendment. It also explained that a cognizable § 1983 claim does not automatically entitle a prisoner to a stay: courts must consider equitable factors, including unnecessary delay and the State’s interest in enforcing its judgment. The Court reversed the Eleventh Circuit and remanded. There were no separate opinions.

Holding

  • Whether Nelson’s challenge to the cut-down procedure is cognizable under § 1983.. Nelson’s Eighth Amendment challenge may proceed under § 1983 because, on the allegations accepted at the pleading stage, enjoining the cut-down procedure would not necessarily prevent Alabama from carrying out his death sentence.
  • Whether stating a cognizable § 1983 claim establishes entitlement to a stay of execution.. A cognizable § 1983 claim does not establish entitlement to a stay. Courts must consider likelihood of success, relative harms, and unnecessary delay, with a strong equitable presumption against a stay when the claim could have been litigated without requiring one.

Docket 03-6821

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