## Facts

- Clarence E. Hill was convicted in Florida of murdering a Pensacola police officer and was sentenced to death; his sentence was affirmed after resentencing and postconviction litigation.
- Florida’s statutory method of execution became lethal injection (unless the inmate elects electrocution).
- Florida used a three-drug lethal-injection protocol.
- After a death warrant scheduled Hill’s execution, he sought information about the protocol and filed suit alleging the three-drug sequence and its administration created a serious risk of severe pain in violation of the Eighth Amendment.
- Hill did not challenge the validity of his conviction or death sentence; he challenged only the particular lethal-injection procedure and asserted the State could use an alternative constitutional method.

## Issues

1. Whether an Eighth Amendment challenge to a State’s lethal-injection protocol that does not contest the validity of the conviction or sentence may be brought under 42 U.S.C. § 1983.
2. Whether such a suit must be treated as a second or successive habeas petition barred by 28 U.S.C. § 2244 when the inmate has already pursued federal habeas relief.

## Decision

- The Supreme Court unanimously reversed the Eleventh Circuit.
- The Court held that Hill’s method-of-execution claim could proceed under 42 U.S.C. § 1983 and was not required to be brought in habeas.
- The Court concluded the claim was not barred as a successive habeas petition under 28 U.S.C. § 2244.
- The Court remanded for further proceedings, without resolving whether Florida’s protocol violated the Eighth Amendment.
- The Court noted that ordinary equitable principles governing injunctive relief and stays, including considerations of delay, remain applicable on remand.

## Legal Principles

- Habeas is generally reserved for claims that, if successful, would invalidate the fact of conviction or the validity of the sentence; § 1983 is available for claims challenging the manner or conditions of carrying out a sentence.
- A method-of-execution claim may proceed under § 1983 when the relief sought would not necessarily prevent the State from implementing the death sentence by other lawful means.
- The availability of § 1983 does not turn on whether the challenge targets an ancillary medical step or the chemical injection sequence itself; the relevant inquiry is whether success would necessarily bar execution.
- Courts addressing method-of-execution § 1983 claims may consider equitable limits on last-minute litigation when deciding whether to grant stays or other injunctive relief.

## Conclusion

The Court held that a condemned prisoner’s Eighth Amendment challenge to a specific lethal-injection protocol may be pursued as a § 1983 action, rather than as a successive habeas petition, when the requested injunction would leave the State able to carry out the death sentence through an alternative lawful method.


Hill v. McDonough, 547 U.S. 573 (2006)