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PL SC 473









Baze v. Rees (2008) Oral

Argument Analysis

Pam Dorian, Blane Barton, Corey Kirkwood

2/27/2011

Page |1







Baze v. Rees (2008)

By Pam Dorian, Blane Barton, Corey Kirkwood



Introduction



In Baze v. Rees, the petitioners challenged lethal injection as unconstitutional under the



Cruel and Unusual Punishment clause of the 8th Amendment. The Kentucky Supreme Court held



previously that the “cocktail” of drugs for lethal injection is not cruel and unusual punishment.



Ultimately, the Supreme Court affirmed the Kentucky Supreme Court’s decision by a 7-2 vote.



Lethal injection, as it’s performed today, is not unconstitutional. The Justices wrote a plurality of



opinions.





Justice Question Totals (Questions 1-3 on the Rubric)



Our number totals varied slightly among group members, but we agreed on the totals in



the chart below.









As you can see, there were 108 questions asked in total. Mr. Verrelli, the petitioner



representing the prisoners, was asked 53 questions by 7 different Justices. Mr. Englert,



representing Kentucky, was asked 39 questions by 4 different Justices. Finally, Mr. Garre,



representing the federal government, was only asked 16 questions total.





Somewhat surprisingly, Justice Souter asked the most questions with 22, while Justice



Scalia was right behind him with 20 questions. Justice Thomas, unsurprisingly, asked the least

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amount with 0 questions. The Justices seemed to question Mr. Verrelli more than the other two



attorneys. Interestingly, Justice Stevens asked all 18 of his questions to Mr. Englert. We address



this fact later in the paper.





As far as interruptions are concerned, my group members and I conflicted in what



constitutes an “interruption.” Ultimately, we concluded that Mr. Verrelli was interrupted 19



times, Mr. Englert was interrupted 14 times, and Mr. Garre was only interrupted 6 times.





Question Topics (4)



Throughout the presentations by the attorneys, a theme developed among the questioning



of the Justices. There was a heavy focus on one particular issue, and it can be summed up in the



question: “Would the petitioners have a case if the first drug was administered properly 100 % of



the time?” While questioning varied off of this point, the crux of this inquiry makes up the most



important argument of the case and the decision of the court seemed to have stemmed from how



adequately they felt this question was answered.



Mr. Verrilli had a string of difficult questions focused on whether the record contained



the evidentiary arguments he was raising before the Court. Mr. Englert faced a difficult series of



questions about the personnel that administer the three drug protocol and particularly, why the



individuals in charge of “pushing the drugs” into the inmate were untrained. The Justices



focused a large part of the conversation with Mr. Garre was on whether the case should be



decided at the current time or if it would be necessary for the case to go back to trial court so



certain questions could be better answered on the record. It seems that going into the oral



argument, the Justices knew what they wanted answers from and heavily focused their



questioning around certain topics, hence why we don't see a lot of variety on this front.

Page |3





Justice Communication (5)



The oral argument of this case shows no instances of Justices communicating through



questioning. Almost every major point of contention was handled by a heavy line of question by



one justice with incursions by some of the other Justices. However, there are no discernible parts



of the argument to point to that show examples of communication among the Justices. Indeed,



they seemed to each be doing their own thing, and didn’t address other Justices.





Stronger Presentation (6)



The ability of an attorney to handle themselves on his/her feet is one of extreme



importance. Giving a speech or a prepared line is not difficult, something that requires only



memorization and possibly polish to appeal to the jury. A true show of skill is the ability of an



attorney to face an onslaught of difficult questions and dispatch them with relative ease, all the



time losing no appearance of confidence. We believe that this same logic can be applied to see



what attorney gave the strongest presentation.



Mr. Garre, while a very confident attorney, is not considered in this for his role was not



the main counsel for either the petitioner or the respondent. Mr. Verrilli starts off and does not



run into too much trouble answering questions, but really takes a beating from Scalia around the



21 minute mark. At this point of the argument, Scalia starts hammering Verrilli's stance and



where he sits on the notion of a constitutional requirement for the “least painful way” in



executions. Verrilli stumbles and is shown to hold contradictory stances, even though he



attempts to deny this. During the question, Verrilli poise in confidence in his voice begins to



wane; he expresses long hesitations, and does not respond with a quick and decisive air of



confidence.

Page |4





Mr. Englert stays quite strong throughout his entire presentation. It is very easy to notice



a difference to how the two attorneys answer questions. Mr. Englert seems to have much more



confidence and decisively begins his answers with a “yes” or “no” before explaining his



reasoning, something that was not seen in Mr. Verrilli's presentation. He also is able to loop



back to questioning of the first attorney and use it to prove a point around 31:58. Mr. Englert is



able to simplify the argument down to the basic point around the administration of the first drug



and provides a persuasive argument in claiming the most qualified person in the state is the one



in charge of that duty. The toughest line of questioning for Mr. Englert concerned the personnel



that administer the drug and if they are qualified or not, a question that the evidence did not seem



to support Englert's position on. However, during the oral argument, Mr. Englert effortlessly



dispatches all questioning around these points and really sets himself apart from Mr. Verrilli.





In general, then, we felt that Mr. Englert and Mr. Garre had a stronger presentation for



the State and federal government, respectfully, than Mr. Verrelli did for the prisoners. However,



Mr. Verrelli probably had a more difficult case to make. Indeed, if the Court had ruled with him,



then it would have affected every State and made it possible for more death penalty cases to



reach the Court under the 8th Amendment. Justice Scalia says this much during the oral



argument.





The Hardest Questions (7)



We believe that the hardest question that faced Mr. Verrilli was the question asked by



Justice Breyer regarding euthanasia (pages 9-10 of the oral argument transcript). The question



came at seven minutes and thirty seconds into the oral argument. Justice Breyer was asking Mr.



Verrilli about euthanasia. Justice Breyer essentially said that you cannot compare euthanasia to



the way they euthanize animals. Justice Breyer also said that he was taken aback by what he had

Page |5





just read from the brief. Mr. Verrilli in response ignores the question by responding “Well, I



think to refer instead to the expert testimony in the case that it is certain to occur in a very few



minutes. Those are the transcript references that we provided at page 18 of the reply brief”



(pages 9-10 of the oral argument transcript). Then Chief Justice Roberts jumps in and asks



whether or not the method has ever been tried and Mr. Verrilli responds with “well it has never



been tried on humans.”





The hardest question that faced Mr. Englert was the question that Justice Stevens asked



about was that he was worried that if they ruled that Kentucky was using the right protocol, then



that would leave one question remaining, and that would be is the second drug used to



unpleasantness by the visitors constitutional (pages 41-42 of the oral argument transcript). He



also goes on to say that the second drug that is administered is the cause of excruciating pain and



that it is really not required to use. Mr. Englert, during these questions, responds only with



saying that the opinion of the Court could go either way and that the second drug is permissible.





Mr. Garre answered all of the questions that the Justices threw at him. The federal



government, it seemed, jumped randomly into the case. Yet Mr. Garre clearly has done this



multiple times, and he was more confident when addressing the Court. He didn’t get caught up at



all and was only asked 16 questions in total.





The Ruling (8)



The Justices at first glance did not seem to be hinting toward any ruling on either side.



However, when we looked at the question totals for each attorney, we suspected that the Justices



would rule in favor of Kentucky. While 8 of the Justices asked Mr. Verrilli a total of 52



questions, only 3 Justices really questioned Mr. Englert for 39 questions. That only 3 Justices

Page |6





questioned the State seemed to indicate that the other 6 of the Justices had little issue with what



they were arguing. Indeed, Justices Souter and Ginsburg asked Englert the most questions, and



they ended up being the only dissenters.





Interestingly, Justice Stevens, a more liberal Justice, asked Mr. Englert a whopping 18



questions, but ended up concurring with the Majority Opinion. In his written opinion, Stevens



agreed with the ruling but questioned the motivation behind the death penalty itself. We think



that he asked Mr. Englert so many questions because he wanted to make sure that, in agreeing



with Kentucky’s argument, he wasn’t inadvertently condoning the death penalty. We also cannot



be sure what happened in the Conference, but perhaps Justice Stevens was swayed somewhat by



another Justice.





Additionally, about 42 minutes and 20 seconds in to the oral argument, Justice Stevens



actually admits that Mr. Englert had a strong case. At this point Justice Stevens actually says to



Mr. Englert, “… the record is very persuasive in your favor, I have to acknowledge” (pages 40-



41 of the oral argument transcript). Justice Stevens also goes on to say, “I... to be very honest



with you, I think that you're... you make a very strong case on the administration in Kentucky on



the record in this case….” (page 41 of the oral argument transcript). When Justice Stevens said



this, we suspected that he was going to vote in favor of the state. We were not surprised by the



courts 7-2 decision in this case. We knew that the most compelling arguments came from the



side of the State.





Humor in the oral argument (9)



There was no humor employed throughout this oral argument. We think that this was



because the case was regarding the death penalty. In other words, there are not many things you

Page |7





can joke about when referring to someone’s fate concerning life or death. Therefore, humor was



not present in the oral arguments of this case.





Conclusion



Baze v. Rees is a very interesting case. At the time of its ruling, it was very much in the



news because nearly every state carries out the death penalty by lethal injection. Therefore, this



case had many implications. As a death penalty case, it lacked certain aspects such as humor, but



for the most part, the oral argument was interesting to listen to.

Page |8





Works Cited

Baze v. Rees, 07-5439 (The Supreme Court January 7, 2008).



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