Penn State International Law Review


Kate E. Bloch

First Paragraph

It was the first day of class. A Department of Justice graph depicting the number of executions performed each year in the United States plastered the white screen at the front of the room. The hills and valleys of the graph flatlined to zero for a number of years in the 1970s. I asked, offhandedly, if anyone in the room could explain why. A student raised her hand and, to my surprise, gave a highly accurate and lucid discussion of the U.S. Supreme Court's reasoning in Furman v. Georgia, the case in which the Court had indeed ruled that capital punishment as imposed was unconstitutional.