Final Project Link

Below is the link for my final project.

www.onlineidentities.weebly.com

Essay 4: When the Online Predator is the Prey

Ryan Higgins

Professor Jasmine Mulliken

English 1113

29 November 2011

When the Online Predator is the Prey

            Several years ago, the NBC program, “To Catch a Predator” opened the world’s eyes to how dangerous online sexual predators can be.  The program showed members of the Perverted Justice organization posing as children in online chat rooms, hoping to lure potential sexual predators into what they thought would be sexual encounters at the children’s homes. When the alleged predators arrived, they were ambushed by an NBC Dateline camera crew and arrested by police.  Reporter Chris Hansen confronted them with embarrassing questions about why they were there.  Many said they had no interest in sex.  They just wanted to talk to the children.  Others were more obvious.  Some stripped their clothes off before the confrontation even began. Some brought liquor or condoms to the homes but still claimed sex was not on their minds.  That argument is highly doubtful, of course.  One thing they all had in common was all of them believed they were chatting online with children when they were really chatting with online impersonators.  The show received high television ratings but many question whether or not creating false online identities to catch these alleged predators is fair.  One argument says it is entrapment, which means the online impersonators unfairly influenced the suspects to behave in a certain way.  Another side of the argument says it is enticement, which is a legal way to catch online sexual predators.  I argue that it is not entrapment when law enforcement officials use false online identities to catch sexual predators.  

            It is not surprising that many of those who argue that catching sexual predators by

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creating false identities online is entrapment are the accused themselves and their lawyers.  Attorney David Shain represents a California man arrested at a city park after arranging to meet an underage girl for sex.  The underage girl was actually a police detective posing online as the girl.  Shain says the police can be guilty of entrapment in some cases.  He argues,“Entrapment rules are drawn fairly narrowly.  It comes down to ‘was the action of law enforcement likely to cause someone to commit a crime they otherwise never would have done?’” (Wilson).  If the answer is yes, Shain argues it is entrapment.  He also argues that no crime actually occurs since the subjects are chatting online with an adult even though they think they are chatting with children.  “Obviously everyone is concerned that children are protected.  But it is somewhat disquieting for a number of us that someone can be prosecuted for a crime that no one committed,” he argues (Wilson).

            Others argue that the idea of putting sexual predators behind bars is important enough to rule out entrapment.  The Virginia Law Review’s Andrew Carlon says the whole idea of entrapment is outdated.  It is not a common defense in other countries; only in America, he argues.  Carlon is frustrated that so many legal resources are used to defining entrapment and deciding whether judges or juries should make rulings in entrapment cases.  “Why should someone who commits a crime, with a criminal state of mind, be found not guilty because the one who tempted him to commit the crime, another otherwise irrelevant fact, was – entirely unbeknownst to him – a police agent?” (Carlon).  Carlon argues that whether it is the case of a detective posing as a child in an online chat room or an officer going undercover in a drug sting, it is not entrapment.                                                                                                                              The idea of entrapment, as Shain argues, often involves the intent of the accused.  The

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Columbia Journalism Review refers to the “To Catch a Predator” program, saying that often during online exchanges with Perverted Justice members posing as children, the alleged predators “express doubts about what they’re doing and have to be egged along a bit by the decoys, many of whom come off as anything but innocent children” (McCollam). In these cases, there is a stronger argument for entrapment because the accused does not seem totally willing to have sex with children.  If the online impersonators start conversations with the accused or change the subject to sex, it could be also considered entrapment in some cases.  However, “they are prepared to flirt, literally, with the line” (McCollam).  Even in cases where the definition of entrapment has obviously taken place, if someone clearly intends to solicit sex with a child, they will often end up in jail even if the child was an online impersonator “so as a legal matter, the enticements offered by the decoys are of little importance to the police,” argues the Columbia Journalism Review.

            Those who argue that these online stings are entrapment point to the legal language that supports their case.  According to the American Journal of Criminal Justice, three questions must be answered to establish entrapment.

1.      Did the law enforcement officer continuously contact the suspect with the intention of trying to convince the individual to engage in a particular type of behavior?

2.     How long was the relationship between the undercover (online) officer and the suspect?

3.     How much, if any reluctance to commit the criminal act did the suspect provide evidence of?  (Hunt, Lee, and Moore).

If the answer to question one is yes, entrapment occurs because the online detective is not legally allowed to influence the potential predators to commit an act, argues the Journal.  Referring to question two, if the online relationship takes place over a long period of time, it is considered

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entrapment.  “Unfortunately, the court did not directly address the issue of what an acceptable time frame would be in regards to sting operations” (Hunt, Lee, and Moore), which makes proving entrapment more difficult.  Finally, if the answer to question three is the suspect was reluctant to commit the act, entrapment is possible, argues the Journal.

            The legal definitions may support the argument for entrapment.  However, those who participate in the online stings argue that the criminals would still engage in the behavior without being influenced, meaning there is no entrapment.  A New York Times article described how police in Long Island, New York are successfully arresting online sexual predators without being accused of entrapment.  Detective Rory Forrestal argues,

            We have a certain way we guide our (online) conversation that keeps us away from that    whole entrapment issue. It’s done very, very strictly, because everything we do is   recorded.  If this guy’s for real, he’s going to be aggressive. The more you lay back, the     better it is for you.  We don’t want some juror saying, ‘Oh, if I was a male, I’d be           attracted.’  You don’t want that. (Richter).

Once again, entrapment goes back to criminal intent.  When sexual predators willingly solicit sex online with whom they perceive as children, it is a criminal act, not entrapment.  It does not matter if the person the subject chats with is actually a child.  If the subject believes it is a child, the criminal intent is present.

            The entrapment issue is relatively new since the Internet and chat rooms are only about 20 years old and their use for police work is even more recent.  “To Catch a Predator” brought the issue to light for many Americans.  In 2006, a CBS News report criticized “To Catch a Predator” for being too sensational and for entrapping its subjects.  NBC anchorman Stone Phillips argued at the time that the show does not entrap its subjects.  CBS blogger Brian Montopoli responded quickly when he argued,

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            Dateline is indeed entrapping the men by having the decoys, at least some of the time,       bring up the subject of sex and later invite the men to the house for a sexual        encounter…if you accept the traditional legal definition of entrapment – that one is           entrapped when ‘induced or persuaded by law enforcement officers or their agents to     commit a crime that he had no previous intent to commit’ – than Phillips’ defense raises   questions, because it was often the decoys who first suggested the crime.

Montopoli was responding directly to Phillips, who said that even though the decoy often initiates the subject of sex, “once the hook is baited, the fish jump and run with it like you wouldn’t believe.” Phillips correctly argued that the alleged sexual predators seen on “To Catch a Predator” do not need to be convinced to have sex with children so there is no entrapment.  The image may be planted in their heads by online impersonators but the subjects themselves are the ones who travel to the homes of whom they believe are children, looking for sex.  Phillips continued his argument.  “Enticement?  Yes.  Entrapment?  I don’t think so.  The closer I look at the online conversations the more obvious it becomes that these men are not first timers when it comes to engaging minor in graphic online chats.  They tend to be remarkably matter-of-fact in their approach, as if it is part of an all too regular routine.”

            Attorneys know that entrapment is very difficult to argue because you must prove that the subject would not have acted that way without online prompting.  Anthony J. Colleluori, a New York defense attorney says most of his clients claim they were entrapped.  However, Colleluori agrees with Phillips when he says his clients were only enticed.  “An officer can entice one otherwise disposed to commit a crime to commit the crime.  That is different from entrapment, defined as an officer overcoming the will of an otherwise unwilling person to commit a crime” (Colleluori).  Enticement is perfectly legal, argues Colleluori.                                                        If an undercover police officer posing as a child online influences someone to solicit sex with the child, it is entrapment, some argue.  Others argue that it is not entrapment because

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anyone who agrees to meet a child for sex is showing an interest in that activity with or without police influence.  The argument will continue to grow as technology progresses and police continue to create new ways to catch online sexual predators.  The predators will not go away.  90 percent of pedophile crimes involve the Internet (Hunt, Lee, and Moore).  Police must use every legal means necessary to catch these predators. 

            It is not entrapment when law enforcement officials use false online identities to catch sexual predators.  Programs such as “To Catch a Predator” may be offensive to some but the end result is what counts.  Sexual predators are being put in jail and it is no one’s fault but their own.  They are being trapped, not entrapped.  Even their lawyers admit that entrapment is difficult to prove because the idea of an adult being influenced to have sex with a child is unbelievable.  An adult who commits this crime will do it without being influenced by someone else, meaning it is not entrapment.  Still, as Hunt, Lee, and Moore argue, “the (entrapment) defense will likely continue to be argued in cases involving online sting operations…the number of such claims is certain to increase as more law enforcement agencies develop online operations and the number of arrests continues to increase.”                                 

           

           

           

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Works Cited

Carlon, Andrew.  “Entrapment, Punishment, and the Sadistic State.”  Virginia Law Review.          June 2007.  Web.  27 Nov. 2011.

Colleluori, Anthony.  “Defending the Internet Sex Sting Case.”  GP Solo.  Jan.-Feb. 2010:             Proquest.  Web.  22 Nov. 2011.

Hunt, Robert;  Lee, Tina; Moore, Robert.  “Entrapped on the Web? Applying the Entrapment     Defense to Cases Involving Sting Operations.”  American Journal of Criminal Justice.    Nov. 2007: Proquest.  Web.  27 Nov. 2011.

McCollam, Douglas.  “The Shame Game.”  Columbia Journalism Review.  Jan.-Feb. 2007:            Proquest.  Web.  22 Nov. 2011.

Montopoli, Brian.  “Does ‘Dateline’ Go Too Far ‘To Catch a Predator’?” CBS News. 7 Feb.        2006.  Web.  27 Nov. 2011.

Phillips, Stone.  “Inside Dateline:  Why It’s Not Entrapment.” MSNBC.  1 Feb. 2006.  Web. 27    Nov. 2011.

Richter, Allan. “Setting the Traps to Snare Online Predators.”  The New York Times.  7 Oct.         2001: Proquest.  Web.  22 Nov. 2011.

Wilson, Tracy.  “Officer Surfs the Net for Sexual Predators.”  Los Angeles Times.  21 Nov. 1999:             Proquest.  Web.  27 Nov. 2011.

Essay 3: A Matter of Life or Death

Ryan Higgins

Professor Jasmine Mulliken

English 1113

3 November 2011

A Matter of Life or Death

            The next presidential election is just over a year away.  The candidates are on the campaign trail, talking about jobs, the economy, and health care.  Sometimes, they talk about their views on abortion.  However, they rarely talk about their stance on an issue that is just as controversial as abortion, the death penalty.  Most people are either strongly for or against the death penalty.  There seems to be little in between.  Two reporters, Liz Goodwin and David Walsh-Little argue against the death penalty.  Goodwin, who writes for The Lookout, describes the story of death row inmate Troy Davis in her blog, “Are Last Minute Supreme Court Stays Cruel and Unusual Punishment?”  Davis was nearly granted a last minute stay before he was put to death.  Walsh-Little, who is also a lawyer, tells the tale of his client, death row inmate John Booth-El, in an America article entitled, “Waiting for Good News.”  Booth-El had already spent 23 years on death row when the article was published in 2007.  Both authors make their argument that the death penalty is wrong by primarily using pathos with some supportive use of logos and ethos.

            It is a good idea to use pathos when arguing for or against a sensitive subject. Emotions can be quite convincing by forcing readers to think with their hearts and their heads.  By illustrating the sad circumstances of their subjects, both authors want the readers to feel sorry for the condemned and agree that the death penalty is wrong.  Goodwin takes the reader to the night of Davis’ execution when she describes in detail everything from his last meal to how we would hopefully “stave off death one more time,” It is difficult for the audience to not feel sympathetic toward a person who is staving off death, no matter what he did to deserve it.  Walsh-Little describes two emotional stories to support his

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argument, which is a wise use of pathos.  Walsh-Little writes about visiting his client, who had been on “Supermax Prison’s” death row for 23 years, a few days before Christmas (Walsh-Little).  It is difficult for the audience to not feel pity for someone spending the holidays on death row, especially if he has been there for 23 years.  It is also a good strategy to reference the holiday season to evoke more sympathy from the readers.  Like Goodwin, Walsh-Little uses imagery to paint a negative picture of death row when he later describes the case of death row inmate Angel Diaz.  Walsh-Little graphically describes Diaz’s execution by writing that the lethal injection needles “were inserted in and through Diaz’s veins, causing the poisonous chemicals to be pumped directly into Diaz’s flesh.  This prolonged the killing process” (Walsh-Little).  His use of pathos is most effective when he continues.  “Witnesses to the execution reported Diaz licking his lips, grimacing, and appearing to speak 24 minutes into the execution.  A second lethal dose of poison was necessary to kill Mr. Diaz, who clearly suffered both unnecessary and severe pain” (Walsh-Little).  The visions of someone suffering a slow and painful death certainly support Walsh-Little’s argument against the death penalty.  The imagery of an execution effectively plays with the audience’s emotions.  It is important to note that neither author went into detail about the crimes the death row inmates committed.  That would make their use of pathos less effective because the audience would not feel as much sympathy for them.  The fallacy in the authors’ use of pathos is the fact that not every death row inmate suffers like the inmates in these articles. Most inmates do not have multiple last minute stays of execution nor have to wait 23 years on death row.  Most inmates also do not suffer terrible pain for half an hour during their executions.       

            Both authors argue against the death penalty but for different reasons.  Goodwin believes multiple stays of execution  and the long waiting period on death row cause unnecessary mental and physical stress, which she calls “cruel and unusual punishment” (Goodwin).  Walsh-Little is more concerned with the methods of execution, which he argues are inhumane.  Despite the fallacy that not all

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death row inmates suffer like the ones mentioned in the articles, both authors use pathos effectively to not only support their argument but also illustrate the reasons for their arguments.

            Both authors rarely and less effectively use logos to support their arguments.  Goodwin provides only two figures.  She says that in 2008, American death row inmates spent an average of 13 years on death row (Goodwin).  This statistic backs up her argument that death row inmates must wait too long for their executions and is an effective use of logos because it logically links her argument with actual numbers.  This statistic could be strong enough to make some readers believe that waiting this long to die is cruel and unusual, which supports Goodwin’s argument.  She uses a comparison with more numbers to try to strengthen her use of logos even more when she writes, “In some countries, waits of more than three years are outlawed as inhumane” (Goodwin).  The use of the word inhumane is an effective use of pathos and comparing the three year wait in some countries to 13 years in the United States could be considered a strong use of logos.  However, the fallacy with this comparison is it is too vague.  Goodwin does not define which countries she means by “some” countries.  What if she is referring to some third world countries whose justice system has little in common with ours?  Also, what does “outlawed as inhumane” really mean?  Does it mean that waits of longer than three years are against the law? 

            Walsh-Little uses logos when he describes some historical information.  He points out that in 2006, Florida Governor Jeb Bush ended all executions in his state because there were too many questions about the pain and suffering of the person being executed (Walsh-Little).  He also cites the story of a federal judge in California, who banned lethal injections, which “raised questions about the legitimacy of capital punishment in principle” (Walsh-Little).  Using historical references to support his argument is an effective use of logos because it provides precedent that supports Walsh-Little’s argument against the death penalty.  In addition to opposing the death penalty because of the methods of

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execution, Walsh-Little supports his argument with other reasoning based on historical references.  He refers to his home state of Maryland, whose governor “declared a moratorium” on the death penalty in 2002 until DNA evidence could be used to make sure those on death row were guilty and because there was evidence of racial bias in death row cases (Walsh-Little).  The fallacy in Walsh-Little’s uses of logos is based on the fact that just because it happened in Florida or Maryland does not mean it should happen everywhere else.  Florida had some trouble with lethal injections but that does not mean all states do.  Maryland had a racial bias problem but does that mean the death penalty should be eliminated everywhere?  Using historical references from specific places weakens the use of logos.

            The authors use logos in different ways.  Goodwin uses statistics while Walsh-Little uses historical references.  Their arguments were not strengthened by the use of logos as much as they are with their uses of pathos.  The statistics need to be more meaningful and the historical references less specific for their use of logos to be more effective.   

            Both authors use ethos to effectively support their arguments.  While Walsh-Little does not directly quote any experts, he describes the actions of some experts in the field to strengthen his argument.  Plus, since he is an experienced lawyer with clients on death row, he can be considered an expert on death penalty cases.  Since Goodwin is not an expert in the field, she effectively quotes authorities such as Amnesty International, Supreme Court Justices Sandra Day O’Connor, Stephen Breyer, and John Paul Stevens, and the UK Privy Council.         

            Goodwin’s most effective use of ethos comes from Justice Breyer, who once argued that the Supreme Court should consider whether the death penalty is cruel and unusual punishment, which is illegal under the Eighth Amendment of the Constitution (Goodwin).  The use of Breyer is powerful when he quotes an 1890 Supreme Court decision.

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When a prisoner sentenced by a court to death is confined in the penitentiary awaiting the   execution of the sentence, one of the most horrible feelings to which he can be subjected during  that time is the uncertainty during the whole of it  (Goodwin).

She effectively ends her article with a quote from the UK Privy Council that said waiting on death row is inhumane because it adds the “additional torture of a long period of alternating hope and despair” (Goodwin).  Goodwin uses these authoritative sources to argue against extended waits on death row, the primary reason she opposes the death penalty.  This is a very effective use of ethos with no fallacies.      Most of Walsh-Little’s use of ethos is in his own words.  As mentioned earlier, he points out the federal judge in California’s decision to ban lethal injections and Maryland Governor Paris Glendening’s moratorium on the death penalty.  The historical reference is a use of logos while the fact that these people are authorities is a use of ethos.  Walsh-Little says in the first paragraph that there is “hope for its (death penalty’s) abolition” (Walsh-Little).  Immediately, his audience knows that he opposes the death penalty.  Later, he describes the death penalty as a sickness that we must confront (Walsh-Little).  However, his most effective words are found in the last sentence of the article, when he refers to the Bible.

             Maybe at the right moment, when leadership is most needed, shepherds like those            described in Luke’s infancy narrative will emerge to announce the good news.  Lord knows, the    abolition of the death penalty in the United States is good news long overdue (Walsh-Little).

Although the audience is not made up of only Christians, the Bible is universally recognized by people from all faiths and even those who have no religious convictions, which makes citing in an allowable use of ethos.

            Both authors make their argument that the death penalty is wrong by primarily using pathos with some limited uses of logos and ethos.  Their strategies and fallacies are similar in that they use pathos and ethos more effectively than logos.  Although there are some fallacies in their use of pathos, such as graphically describing only three death row inmates, overall it is an effective rhetorical device because it

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elicits emotion from the readers.  Many people base their decisions on emotions.  The authors do not use logos as effectively because although the statistics sound convincing, the fallacy is they are very vague.  Finally, the use of ethos is perhaps the most effective rhetorical device because there are few, if any fallacies.  Goodwin uses quotes from respected experts since she is not an expert herself.  These powerful words support her argument against the death penalty well.  Walsh-Little has an advantage over Goodwin since he is an expert himself.  Although it is clear that Goodwin opposes the death penalty, especially the long waiting periods, she never comes out and actually says it.  On the other hand, Walsh-Little leaves no doubt with his final comments about abolition of the death penalty being long overdue. 

           

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Works Cited

Goodwin, Liz.  “Are Last-Minute Supreme Court Stays Cruel and Unusual Punishment?”   

                        Yahoo! News.  Yahoo! Inc., 21 Sept. 2011. Web. 29 Sept. 2011. 

Walsh-Little, David.  “Waiting for Good News.”  America.  10 Dec. 2007: Academic Search

                        Premier.  Web.  2 Nov. 2011.

Essay 2: The Waiting Game

Ryan Higgins

Professor Jasmine Mulliken

English 1113

4 October 2011

The Waiting Game

            The waiting is the hardest part.  That is what Tom Petty and the Heartbreakers sing about in a classic song by the band.  It is also what Liz Goodwin, a reporter for The Lookout, writes about in her blog, “Are Last Minute Supreme Court Stays Cruel and Unusual Punishment?”  Goodwin describes the story of Troy Davis, a Georgia Death Row inmate, who awaited his execution on September 21.  After a last-minute appeal, the U.S. Supreme Court delayed his execution as it considered whether or not to grant a stay.  His appeal was unsuccessful and Davis was put to death a few hours later.  The Lookout is a Yahoo! News blog with a small staff of reporters, such as Goodwin, who is listed as The Lookout’s “national affairs reporter.”  Goodwin takes the readers through the execution night to paint a picture of what Davis must have been going through.  Her choice of words and pictures on the blog site also support her argument that it is wrong to prolong a death sentence.  She also cites statistics from other executions.  Goodwin uses pathos and logos to argue that it is cruel and unusual to make death row inmates wait until the last minute to find out their fate.

            When writing about a controversial subject such as the death penalty, it is natural to use pathos to support the argument.  Goodwin effectively uses pathos by choosing an emotional subject like the death penalty for her blog.  People have a strong opinion, whether they are for or against the death penalty.  Goodwin wants the readers to feel sorry for Davis when she describes how he ate “his last meal” the night of the execution and how “his supporters celebrated and prayed, hoping that the delay meant Davis would stave off death one more time” (Goodwin). 

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The thought of someone’s last meal and staving off death makes the reader want to support Davis.  She later says Davis was, “strapped to a gurney and put to death,” which creates a negative image in the reader’s minds.  Goodwin never tells the readers what Davis was convicted of so they have no reason to dislike Davis.  If they did dislike him, Goodwin’s use of pathos would not be as effective.

Goodwin’s main argument is not to stop the death penalty but to stop making death row inmates wait until the last minute for a stay.  She argues, “…another issue raised by Davis’ roller-coaster ride through state-mandated life and death over the past 20 years is whether Death Row itself constitutes cruel and unusual punishment” (Goodwin).  Goodwin believes that Death Row inmates should not have to play the waiting game with appeals and last minute stays because it is too emotionally stressful.  Her use of pathos to support her argument continues when she describes how members of Amnesty International compare multiple last minute stays of execution to “ ‘mock executions’ – a practice widely recognized as torture” (Goodwin).  Goodwin’s use of pathos is not limited to her words.  The blog also features a picture of Davis in 1991.  He is wearing a suit and looks like a model citizen, not someone convicted of a crime.  Using a picture of a younger and clean-cut Davis is a way to make the readers feel more sympathy toward him.  There is another picture of people crying.  There is no caption saying they are crying for Davis but readers are led to assume they are.  Showing pictures that cause emotion in the readers is a use of pathos.

  Goodwin uses logos when providing background information about Davis’ past legal history.  Goodwin cites three previous times when Davis avoided execution at the last minute.  She hopes that the readers will think three previous stays are unreasonable and agree with her argument.  Goodwin supports her argument with more statistics, another use of logos.  She says

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that in 2008, Death Row inmates “spent an average of 13 years waiting for their executions” (Goodwin).  Goodwin uses quotes from Supreme Court justices as well, including the argument from Justice Stephen Breyer, who, in 1995 said that the Supreme Court should consider whether the idea of Death Row is cruel and unusual punishment, which would be against the Eighth Amendment of the Constitution.  In the blog’s final paragraph, Goodwin explains how some countries change the death penalty to life in prison if the execution does not happen within three years of sentencing.  This citing of statistics, quotes from authorities, and historical examples from other countries that use the death penalty are logical ways for Goodwin to support her argument and an effective use of logos.

            The Lookout is not as thorough as Time or Newsweek.  The blogs are short and comments are welcomed.  The intended audience wants its news quickly without a lot of details.  Blogs are usually read by younger people who know how to use technology while older people tend to read newspapers and other print materials.  By using mostly pathos, Goodwin captures the emotions of young adults who might be more easily influenced than older people.  She supports her argument with the use of logos by providing enough facts.  People who are interested in current events are most likely to read this blog.  They are informed about the world and need facts to influence their decisions.  Also, since Goodwin is not a recognized authority on the death penalty, she must use facts to give her credibility to the readers.  A week after the blog was written there were 2,476 comments posted, which proves that the readers formed an opinion from Goodwin’s argument. 

            Goodwin makes use of pathos and logos to argue that last minute stays of execution are cruel and unusual.  She is not necessarily opposed to the death penalty but is opposed to the extended waiting period Death Row prisoners face.  She uses strong words to grab the emotions

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of young adult readers.  Goodwin cites enough statistical and factual information to back up her argument for those who are familiar with current events.  Since Goodwin is not a recognized authority on the death penalty, she cannot use ethos effectively unless she quotes experts on the subject of the death penalty.  She concludes her blog with a combination of pathos and ethos.  Goodwin says the 1989 European Court of Human Rights called Death Row inhumane because of “the anguish and mounting tension of living in the ever-present shadow of death” (Goodwin).  Those are emotional but authoritative words since they came from the European court of Human Rights.  Finally, she effectively uses ethos when ending her blog with a powerful quote from an authority.  In this case, the quote is from the United Kingdom Privy Council, which said a long stay on Death Row is inhumane because it means “additional torture of a long period of alternating hope and despair” (Goodwin).

           

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Work Cited

Goodwin, Liz.  “Are Last-Minute Supreme Court Stays Cruel and Unusual Punishment?”   

                        Yahoo! News.  Yahoo! Inc., 21 Sept. 2011. Web. 29 Sept. 2011.