Supreme Court of the United States
Hill v. McDonough, Interim Secretary, Florida Department of Corrections
June 12, 2006547 U.S. 573
Summary
The Supreme Court held that Clarence Hill's challenge to Florida's three-drug lethal injection protocol may proceed as a civil rights action under 42 U.S.C. § 1983 rather than as a petition for writ of habeas corpus, because the injunction he seeks would not necessarily prevent the State from executing him by lethal injection through an alternative, lawful procedure. Applying Nelson v. Campbell, the Court rejected proposals that capital litigants be required to identify an acceptable alternative execution method or that suits which practically frustrate an execution be recharacterized as habeas petitions, while stressing that a stay of execution remains a discretionary equitable remedy subject to demanding standards. The Court reversed the Eleventh Circuit and remanded, leaving the merits and equities of Hill's claim unaddressed.
Holding
- Whether Hill's challenge to Florida's lethal injection protocol must proceed as a habeas petition under 28 U.S.C. § 2254 or may proceed under 42 U.S.C. § 1983.. Hill's § 1983 action is controlled by the holding in Nelson v. Campbell and may proceed under § 1983, because a grant of the injunctive relief he seeks would not necessarily prevent the State from executing him by lethal injection and thus would not necessarily invalidate the sentence.
- Whether a § 1983 challenger to an execution procedure must identify an acceptable alternative method of execution, or whether suits that would practically frustrate an execution must be treated as habeas petitions.. Neither limitation may be imposed. Nelson's plaintiff's identification of an acceptable alternative supported but was not decisive of the result; Nelson did not change the traditional pleading requirements for § 1983 actions, and heightened pleading requirements may not be created case-by-case. Nor can a 'functional' frustration test be squared with Nelson's criterion—whether relief would necessarily imply the invalidity of the sentence—which is consistent with the Heck line of damages cases.
- What equitable constraints govern stays of execution sought in connection with § 1983 challenges to the manner of execution.. A stay of execution is an equitable remedy, not available as a matter of right; inmates seeking time to challenge the manner of execution must satisfy all requirements for a stay, including a significant possibility of success on the merits, and courts must apply a strong equitable presumption against granting a stay where a claim could have been brought early enough to consider the merits without a stay. Federal courts can and should protect States from dilatory or speculative suits without rejecting Nelson.
Docket 05-8794
Cited authorities
- Fla. Stat. §§922.105
- CA11
- 42 U.S.C. § 1983
- 28 U.S.C. §2254
- 42 U.S.C. § 1983
- 42 U.S.C. § 1983
- 28 U.S.C. § 2244
- 28 U.S.C. § 2254
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