document_title: Capital punishment in the United States

question_text: what method of execution is used in most states

question_tokens: what method of execution is used in most states

text: Capital punishment in the United States

text: History[edit]

text: Pre-Furman history[edit]

text: The first recorded death sentence in the British North American colonies was carried out in 1608 on Captain George Kendall,[10] who was executed by firing squad[11] at the Jamestown colony for spying for the Spanish government.[12]

text: The Bill of Rights adopted in 1789 included the Eighth Amendment which prohibited cruel and unusual punishment. The Fifth Amendment was drafted with language implying a possible use of the death penalty, requiring a grand jury indictment for "capital crime" and a due process of law for deprivation of "life" by the government.[13] The Fourteenth Amendment adopted in 1868 also requires a due process of law for deprivation of life by any states.

text: The Espy file,[14] compiled by M. Watt Espy and John Ortiz Smykla, lists 15,269 people executed in the United States and its predecessor colonies between 1608 and 1991. From 1930 to 2002, there were 4,661 executions in the U.S., about two-thirds of them in the first 20 years.[15] Additionally, the United States Army executed 135 soldiers between 1916 and 1955 (the most recent).[16][17][18]

text: Early abolition movement[edit]

text: Three states abolished the death penalty for murder during the 19th century: Michigan (which has never executed a prisoner since achieving statehood) in 1846, Wisconsin in 1853 and Maine in 1887. Rhode Island is also a state with a long abolitionist background, having repealed the death penalty in 1852, though it was theoretically available for murder committed by a prisoner between 1872 and 1984.

text: Other states which abolished the death penalty for murder before Gregg v. Georgia include: Minnesota in 1911, Vermont in 1964, Iowa and West Virginia in 1965 and North Dakota in 1973. Hawaii abolished the death penalty in 1948 and Alaska in 1957, both before their statehood. Puerto Rico repealed it in 1929 and the District of Columbia in 1981. Arizona and Oregon abolished the death penalty by popular vote in 1916 and 1964 respectively, but both reinstated it, again by popular vote, some years later: Arizona in 1918 and Oregon in 1978.[19] Puerto Rico and Michigan are the only two U.S. jurisdictions to have explicitly prohibited capital punishment in their constitutions: in 1952 and 1964, respectively.

text: Constitutional law developments[edit]

text: Nevertheless, capital punishment continued to be used by a majority of states and the federal government for various crimes, especially murder and rape, from the creation of the United States up to the beginning of the 1960s. Until then, "save for a few mavericks, no one gave any credence to the possibility of ending the death penalty by judicial interpretation of constitutional law", according to abolitionist Hugo Bedau.[20]

text: The possibility of challenging the constitutionality of the death penalty became progressively more realistic after the Supreme Court of the United States decided Trop v. Dulles in 1958, when the court said explicitly for the first time that the Eighth Amendment's cruel and unusual clause must draw its meaning from the "evolving standards of decency that mark the progress of a maturing society", rather than from its original meaning. Also in the 1932 case Powell v. Alabama, the court made the first step of what would later be called "death is different" jurisprudence, when it held that any indigent defendant was entitled to a court-appointed attorney in capital cases - a right that was only later extended to non-capital defendants in 1963, with Gideon v. Wainwright.

text: Capital punishment suspended (1972)[edit]

text: In Furman v. Georgia, the U.S. Supreme Court considered a group of consolidated cases. The lead case involved an individual convicted under Georgia's death penalty statute, which featured a "unitary trial" procedure in which the jury was asked to return a verdict of guilt or innocence and, simultaneously, determine whether the defendant would be punished by death or life imprisonment. The last pre-Furman execution was that of Luis Monge on June 2, 1967.

text: In a 5-4 decision, the Supreme Court struck down the impositions of the death penalty in each of the consolidated cases as unconstitutional in violation of the Eighth and Fourteenth Amendments of the United States Constitution. The Supreme Court has never ruled the death penalty to be per se unconstitutional. The five justices in the majority did not produce a common opinion or rationale for their decision, however, and agreed only on a short statement announcing the result. The narrowest opinions, those of Byron White and Potter Stewart, expressed generalized concerns about the inconsistent application of the death penalty across a variety of cases, but did not exclude the possibility of a constitutional death penalty law. Stewart and William O. Douglas worried explicitly about racial discrimination in enforcement of the death penalty. Thurgood Marshall and William J. Brennan Jr. expressed the opinion that the death penalty was proscribed absolutely by the Eighth Amendment as cruel and unusual punishment.

text: The Furman decision caused all death sentences pending at the time to be reduced to life imprisonment, and was described by scholars as a "legal bombshell".[4] The next day, columnist Barry Schweid wrote that it was "unlikely" that the death penalty could exist anymore in the United States.[21]

text: Capital punishment reinstated (1976)[edit]

text: Instead of abandoning capital punishment, 37 states enacted new death penalty statutes that attempted to address the concerns of White and Stewart in Furman. Some states responded by enacting mandatory death penalty statutes which prescribed a sentence of death for anyone convicted of certain forms of murder. White had hinted that such a scheme would meet his constitutional concerns in his Furman opinion. Other states adopted "bifurcated" trial and sentencing procedures, with various procedural limitations on the jury's ability to pronounce a death sentence designed to limit juror discretion.

text: On July 2, 1976, the U.S. Supreme Court decided Gregg v. Georgia[22] and upheld 7-2 a Georgia procedure in which the trial of capital crimes was bifurcated into guilt-innocence and sentencing phases. At the first proceeding, the jury decides the defendant's guilt; if the defendant is innocent or otherwise not convicted of first-degree murder, the death penalty will not be imposed. At the second hearing, the jury determines whether certain statutory aggravating factors exist, whether any mitigating factors exist, and, in many jurisdictions, weigh the aggravating and mitigating factors in assessing the ultimate penalty - either death or life in prison, either with or without parole. The same day, in Woodson v. North Carolina[23] and Roberts v. Louisiana,[24] the court struck down 5-4 statutes providing a mandatory death sentence.

text: Executions resumed on January 17, 1977, when Gary Gilmore went before a firing squad in Utah. Although hundreds of individuals were sentenced to death in the United States during the 1970s and early 1980s, only ten people besides Gilmore (who had waived all of his appeal rights) were actually executed prior to 1984.

text: Supreme Court narrows capital offenses[edit]

text: In 1977, the Supreme Court's Coker v. Georgia decision barred the death penalty for rape of an adult woman. Previously, the death penalty for rape of an adult had been gradually phased out in the United States, and at the time of the decision, Georgia and the U.S. Federal government were the only two jurisdictions to still retain the death penalty for that offense.

text: In the 1980 case Godfrey v. Georgia, the U.S. Supreme Court ruled that murder can be punished by death only if it involves a narrow and precise aggravating factor.[25]

text: The U.S. Supreme Court has placed two major restrictions on the use of the death penalty. First, the case of Atkins v. Virginia, decided on June 20, 2002,[26] held that the execution of intellectually disabled inmates is unconstitutional. Second, in 2005, the court's decision in Roper v. Simmons[27] struck down executions for offenders under the age of 18 at the time of the crime.

text: In the 2008 case Kennedy v. Louisiana, the court also held 5-4 that the death penalty is unconstitutional when applied to non-homicidal crimes against the person, including child rape. Only two death row inmates (both in Louisiana) were affected by the decision.[28] Nevertheless, the ruling came less than five months before the 2008 presidential election and was criticized by both major party candidates Barack Obama and John McCain.[29]

text: Repeal movements and legal challenges[edit]

text: In 2004, New York and Kansas capital sentencing schemes were struck down by their respective state highest courts. Kansas successfully appealed the Kansas Supreme Court decision to the United States Supreme Court, who reinstated the statute in Kansas v. Marsh (2006), holding it did not violate the U.S. Constitution. The decision of New York Court of Appeals was based on the state constitution, making unavailable any appeal. The state lower house has since blocked all attempts to reinstate the death penalty by adopting a valid sentencing scheme.[30] In 2016, Delaware's death penalty statute was also struck down by its state supreme court.[31]

text: In 2007, New Jersey became the first state to repeal the death penalty by legislative vote since Gregg v. Georgia,[32] followed by New Mexico in 2009,[33][34] Illinois in 2011,[35] Connecticut in 2012,[36][37] and Maryland in 2013.[38] The repeals were not retroactive, but in New Jersey, Illinois and Maryland, governors commuted all death sentences after enacting the new law.[39] In Connecticut, the Connecticut Supreme Court ruled in 2015 that the repeal must be retroactive. New Mexico is the only state with remaining death row inmates and no present death penalty statute.[40]

text: Nebraska's legislature also passed a repeal in 2015, but a referendum campaign gathered enough signatures to suspend it. Capital punishment was reinstated by popular vote on November 8, 2016. The same day, California's electorate defeated a proposal to repeal the death penalty, and adopted another initiative to speed up its appeal process.[41]

text: Since Furman, 11 states have organized popular votes dealing with the death penalty through the initiative and referendum process. All resulted in a vote for reinstating it, rejecting its abolition, expanding its application field, specifying in the state constitution that it is not unconstitutional, or expediting the appeal process in capital cases.[19]

text: States that have abolished the death penalty[edit]

text: 19 states, plus the District of Columbia and Puerto Rico have abolished the death penalty for all crimes. Below is a table of the 19 states and the date that the state abolished the death penalty.[42][43][44][45][46]

text:
State

Year

Alaska

1957

Connecticut

2012

Delaware

2016

District of Columbia

1981

Hawaii

1957

Illinois

2011

Iowa

1965

Maine

1887

Maryland

2013

Massachusetts

1984

Michigan

1846

Minnesota

1911

New Jersey

2007

New Mexico

2009

New York

2007

North Dakota

1975

Rhode Island

1984

Puerto Rico

1929

Vermont

1972

West Virginia

1965

Wisconsin

1853

text: Lethal injection era[edit]

text: From 1976 to July 1, 2018, there were 1,477 executions, of which 1,302 were by lethal injection, 158 by electrocution, 11 by gas inhalation, 3 by hanging, and 3 by firing squad.[47] The South had the great majority of these executions, with 1,207; there were 181 in the Midwest, 85 in the West, and only 4 in the Northeast. No state in the Northeast has conducted an execution since Connecticut, now abolitionist, in 2005. The state of Texas alone conducted 552 executions, over 1/3 of the total; the states of Texas, Virginia, and Oklahoma combined make up over half the total, with 777 executions between them.[48] 3 executions have been conducted by the federal government, the last in 2003. Executions increased in frequency until 1999; 98 prisoners were executed that year. Since 1999, the number of executions has greatly decreased, and the 20 executions in 2016 were the fewest since 1991.[6]

text: The death penalty was a notable issue during the 1988 presidential election. It came up in the October 13, 1988, debate between the two presidential nominees George H. W. Bush and Michael Dukakis, when Bernard Shaw, the moderator of the debate, asked Dukakis, "Governor, if Kitty Dukakis [his wife] were raped and murdered, would you favor an irrevocable death penalty for the killer?" Dukakis replied, "No, I don't, and I think you know that I've opposed the death penalty during all of my life. I don't see any evidence that it's a deterrent, and I think there are better and more effective ways to deal with violent crime." Bush was elected, and many, including Dukakis himself, cite the statement as the beginning of the end of his campaign.[49]

text: In 1996, Congress passed the Antiterrorism and Effective Death Penalty Act to streamline the appeal process in capital cases. The bill was signed into law by President Bill Clinton, who had endorsed capital punishment during his 1992 presidential campaign.

text: A study found that at least 34 of the 749 executions carried out in the U.S. between 1977 and 2001, or 4.5%, involved "unanticipated problems or delays that caused, at least arguably, unnecessary agony for the prisoner or that reflect gross incompetence of the executioner". The rate of these "botched executions" remained steady over the period.[50] A study published in The Lancet in 2005 found that in 43% of cases of lethal injection, the blood level of hypnotics in the prisoner was insufficient to ensure unconsciousness.[51] Nonetheless, the Supreme Court ruled in 2008 (Baze v. Rees) and again in 2015 (Glossip v. Gross) that lethal injection does not constitute cruel and unusual punishment.[52]

text: Women's history and capital punishment[edit]

text: In 1632, 24 years after the first recorded male execution in the colonies, Jane Champion became the first woman to be lawfully executed.[53] She was sentenced to death by hanging after she was convicted of murder in front of a grand jury.[54] The second half of the 17th century saw the executions of 14 women and 6 men who were accused of witchcraft during the witch hunt hysteria and the Salem Witch Trials.  While both men and women were  executed, 80% of the accusations were towards women, so the list of executions disproportionately affected men by a margin of 6 (actual) to 4 (expected), i.e. 50% more men were executed than expected from the percentage of accused who were men.[55]

text: Other notable female executions include Mary Surratt, Margie Velma Barfield and Wanda Jean Allen.  Mary Surratt was executed by hanging in 1865 after being convicted of co-conspiring to assassinate Abraham Lincoln.[56] Margie Velma Barfield was convicted of murder and when she was executed by lethal injection in 1984, she became the first woman to be executed since the ban on capital punishment was lifted in 1976.[57] Wanda Jean Allen was convicted of murder in 1989 and had a high-profile execution by lethal injection in January 2001.  She was the first black woman to be executed in the US since 1954.[58]  According to Allen's lawyers, prosecutors capitalized on her low IQ, race and homosexuality in their representations of her as a murderer at trial.[59]

text: Capital crimes[edit]

text: Aggravated murder[edit]

text:
Aggravating factors for seeking capital punishment of murder vary greatly among death penalty states. California has twenty-two;[60] New Hampshire has seven.[61]
Some aggravating circumstances are nearly universal, such as robbery-murder, murder involving rape of the victim, and murder of an on-duty police officer.[62]

text: Several states have included child murder to their list of aggravating factors, but the victim's age under which the murder is punishable by death varies. In 2011, Texas raised this age from six to ten.[63]

text: In some states, the high number of aggravating factors has been criticized on account of giving prosecutors too much discretion in choosing cases where they believe capital punishment is warranted. In California especially, an official commission proposed, in 2008, to reduce these factors to five (multiple murders, torture murder, murder of a police officer, murder committed in jail, and murder related to another felony).[64] Columnist Charles Lane went further, and proposed that murder related to a felony other than rape should no longer be a capital crime when there is only one victim killed.[65]

text: Aggravating factors[edit]

text: In order for a person to be eligible for a death sentence when convicted of aggravated first-degree murder, the jury or court (when there is not a jury) must determine at least one of sixteen aggravating factors that existed during the crime's commission. The following is a list of the 16 aggravating factors.[66]

text:
Murder while committing another felony.[67]
Offender was convicted of a separate felony involving a firearm prior to the aggravated murder.
Being convicted of a separate felony where death or life imprisonment was authorized prior to the aggravated murder.
Being convicted of any separate violent felony prior to the aggravate murder.
The offender put the lives of at least 1 or more other persons in danger of death during the commission of the crime.
Offender committed the crime in an especially cruel, heinous, or depraved manner.
Offender committed the crime for financial gain.
Offender committed the crime for monetary gain.
The murder was premeditated, involved planning in order to be carried out, or the offender showed early signs of committing the crime, such as keeping a journal of the crime's details[68] and posting things on the Internet.[69]
Offender was previously convicted of at least two drug offenses.
The victim would not have been able to defend themselves while being attacked.
Offender was previously convicted of a federal drug offense.
Offender was involved in a long-term business of selling drugs to minors.
A high-ranking official was murdered, such as the President of the United States, the leader of another country, or a police officer.
Offender was previously convicted of sexual assault or child rape.
During the crime's commission, the offender killed or tried to kill multiple people.[70]

text: Crimes against the state[edit]

text: The opinion of the court in Kennedy v. Louisiana says that the ruling does not apply to "treason, espionage, terrorism, and drug kingpin activity, which are offenses against the State".[71]

text: Since no one is on death row for such offenses, the court has yet to rule on the constitutionality of the death penalty applied for them.

text: Treason, espionage and large-scale drug trafficking are all capital crimes under federal law. Treason is also punishable by death in six states (Arkansas, California, Georgia, Louisiana, Mississippi, and Missouri). Vermont still has a pre-Furman statute providing the death penalty for treason despite removing capital punishment for murder in 1965.[72] Large-scale drug trafficking is punishable by death in two states (Florida and Missouri).[73] Aircraft hijacking is a capital crime in Georgia and Mississippi.

text: Legal process[edit]

text: The legal administration of the death penalty in the United States typically involves five critical steps: (1) prosecutorial decision to seek the death penalty (2) sentencing, (3) direct review, (4) state collateral review, and (5) federal habeas corpus.

text: Clemency, through which the Governor or President of the jurisdiction can unilaterally reduce or abrogate a death sentence, is an executive rather than judicial process.[74]

text: Decision to seek the death penalty[edit]

text: While judges in criminal cases can usually impose a harsher prison sentence than the one demanded by prosecution, the death penalty can be handed down only if the accuser has specifically decided to seek it.

text: In the decades since Furman, new questions have emerged about whether or not prosecutorial arbitrariness has replaced sentencing arbitrariness. A study by Pepperdine University School of Law published in Temple Law Review, surveyed the decision-making process among prosecutors in various states. The authors found that prosecutors' capital punishment filing decisions remain marked by local "idiosyncrasies", suggesting they are not in keeping with the spirit of the Supreme Court's directive. This means that "the very types of unfairness that the Supreme Court sought to eliminate" may still "infect capital cases". Wide prosecutorial discretion remains because of overly broad criteria. California law, for example, has 22 "special circumstances", making nearly all premeditated murders potential capital cases.[75]

text: A proposed remedy against prosecutorial arbitrariness is to transfer the prosecution of capital cases to the state attorney general.[76]

text: Sentencing[edit]

text: Of the 31 states with the death penalty, 28 provide the sentence to be decided by a jury, and 28 require a unanimous sentence.

text: The only state which does not require a unanimous jury decision is Alabama. In Alabama, at least 10 jurors must concur. A retrial happens if the jury deadlocks.[77]

text: Nebraska is the only state in which the sentence is decided by a three-judge panel. If one of the judges on the panel opposes death, the defendant is sentenced to life imprisonment.[78]

text: Montana is the only state where the trial judge decides the sentence alone.[79]

text: In all states in which the jury is involved, only death-qualified veniremen can be selected in such a jury, to exclude both people who will always vote for the death sentence and those who are categorically opposed to it.

text: However, the states differ on what happens if the penalty phase results in a hung jury:[80][81]

text:
In four states (Arizona, California, Kentucky and Nevada), a retrial of the penalty phase will be conducted before a different jury (the common-law rule for mistrial).[82]
In two states (Indiana and Missouri), the judge will decide the sentence.
In the 22 other states, a hung jury results in a life sentence, even if only one juror opposed death. Federal law also provides that outcome.

text: The first outcome is referred as the "true unanimity" rule, while the third has been criticized as the "single-juror veto" rule.[83]

text: Direct review[edit]

text: If a defendant is sentenced to death at the trial level, the case then goes into a direct review.[84] The direct review process is a typical legal appeal. An appellate court examines the record of evidence presented in the trial court and the law that the lower court applied and decides whether the decision was legally sound or not.[85] Direct review of a capital sentencing hearing will result in one of three outcomes. If the appellate court finds that no significant legal errors occurred in the capital sentencing hearing, the appellate court will affirm the judgment, or let the sentence stand.[84] If the appellate court finds that significant legal errors did occur, then it will reverse the judgment, or nullify the sentence and order a new capital sentencing hearing.[86] Lastly, if the appellate court finds that no reasonable juror could find the defendant eligible for the death penalty, a rarity, then it will order the defendant acquitted, or not guilty, of the crime for which he/she was given the death penalty, and order him sentenced to the next most severe punishment for which the offense is eligible.[86] About 60 percent survive the process of direct review intact.[87]

text: State collateral review[edit]

text: At times when a death sentence is affirmed on direct review, supplemental methods to attack the judgment, though less familiar than a typical appeal, do remain. These supplemental remedies are considered collateral review, that is, an avenue for upsetting judgments that have become otherwise final.[88] Where the prisoner received his death sentence in a state-level trial, as is usually the case, the first step in collateral review is state collateral review, which is often called state habeas corpus. (If the case is a federal death penalty case, it proceeds immediately from direct review to federal habeas corpus.) Although all states have some type of collateral review, the process varies widely from state to state.[89] Generally, the purpose of these collateral proceedings is to permit the prisoner to challenge his sentence on grounds that could not have been raised reasonably at trial or on direct review.[90] Most often, these are claims, such as ineffective assistance of counsel, which requires the court to consider new evidence outside the original trial record, something courts may not do in an ordinary appeal. State collateral review, though an important step in that it helps define the scope of subsequent review through federal habeas corpus, is rarely successful in and of itself. Only around 6 percent of death sentences are overturned on state collateral review.[91]

text: In Virginia, state habeas corpus for condemned men are heard by the state supreme court under exclusive original jurisdiction since 1995, immediately after direct review by the same court.[92] This avoids any proceeding before the lower courts, and is in part why Virginia has the shortest time on average between death sentence and execution (less than eight years) and has executed 113 offenders since 1976 with only five remaining on death row as of June 2017.[93][94]

text: To reduce litigation delays, other states require convicts to file their state collateral appeal before the completion of their direct appeal,[95] or provide adjudication of direct and collateral attacks together in a "unitary review".[96]

text: Federal habeas corpus[edit]

text: After a death sentence is affirmed in state collateral review, the prisoner may file for federal habeas corpus, which is a unique type of lawsuit that can be brought in federal courts. Federal habeas corpus is a type of collateral review, and it is the only way that state prisoners may attack a death sentence in federal court (other than petitions for certiorari to the United States Supreme Court after both direct review and state collateral review). The scope of federal habeas corpus is governed by the Antiterrorism and Effective Death Penalty Act of 1996 (AEDPA), which restricted significantly its previous scope. The purpose of federal habeas corpus is to ensure that state courts, through the process of direct review and state collateral review, have done a reasonable job in protecting the prisoner's federal constitutional rights. Prisoners may also use federal habeas corpus suits to bring forth new evidence that they are innocent of the crime, though to be a valid defense at this late stage in the process, evidence of innocence must be truly compelling.[97] According to Eric Freedman, 21 percent of death penalty cases are reversed through federal habeas corpus.[91]

text: James Liebman, a professor of law at Columbia Law School, stated in 1996 that his study found that when habeas corpus petitions in death penalty cases were traced from conviction to completion of the case, there was "a 40 percent success rate in all capital cases from 1978 to 1995".[98] Similarly, a study by Ronald Tabak in a law review article puts the success rate in habeas corpus cases involving death row inmates even higher, finding that between "1976 and 1991, approximately 47 percent of the habeas petitions filed by death row inmates were granted".[99] The different numbers are largely definitional, rather than substantive: Freedam's statistics looks at the percentage of all death penalty cases reversed, while the others look only at cases not reversed prior to habeas corpus review.

text: A similar process is available for prisoners sentenced to death by the judgment of a federal court.[100]

text: The AEDPA also provides an expeditious habeas procedure in capital cases for states meeting several requirements set forth in it concerning counsel appointment for death row inmates.[101] Under this program, federal habeas corpus for condemned prisoners would be decided in about three years from affirmance of the sentence on state collateral review. In 2006, Congress conferred the determination of whether a state fulfilled the requirements to the U.S. attorney general, with a possible appeal of the state to the United States Court of Appeals for the District of Columbia Circuit. As of March 2016, the Department of Justice has still not granted any certifications.[102]

text: Section 1983[edit]

text: If the federal court refuses to issue a writ of habeas corpus, the death sentence becomes final for all purposes. In recent times, however, prisoners have postponed execution through another way of federal litigation using the Civil Rights Act of 1871 - codified at 42 U.S.C. § 1983 - which allows people to bring lawsuits against state actors to protect their federal constitutional and statutory rights.

text: While the aforementioned appeals are normally limited to one and automatically stay the execution of the death sentence, Section 1983 lawsuits are unlimited, but the petitioner will be granted a stay of execution only if the court believes he has a likelihood of success on the merits.[103]

text: Traditionally, Section 1983 was of limited use for a state prisoner under sentence of death because the Supreme Court has held that habeas corpus, not Section 1983, is the only vehicle by which a state prisoner can challenge his judgment of death.[104] In the 2006 Hill v. McDonough case, however, the United States Supreme Court approved the use of Section 1983 as a vehicle for challenging a state's method of execution as cruel and unusual punishment in violation of the Eighth Amendment. The theory is that a prisoner bringing such a challenge is not attacking directly his judgment of death, but rather the means by which that the judgment will be carried out. Therefore, the Supreme Court held in the Hill case that a prisoner can use Section 1983 rather than habeas corpus to bring the lawsuit. Yet, as Clarence Hill's own case shows, lower federal courts have often refused to hear suits challenging methods of execution on the ground that the prisoner brought the claim too late and only for the purposes of delay. Further, the Court's decision in Baze v. Rees, upholding a lethal injection method used by many states, has narrowed the opportunity for relief through Section 1983.

text: Execution warrant[edit]

text: While the execution warrant is issued by the governor in several states, in the vast majority it is a judicial order, issued by a judge or by the state supreme court at the request of the prosecution.

text: The warrant usually sets an execution day. Some states instead provide a longer period, such as a week or 10 days to carry out the execution. This is designated to avoid issuing a new warrant in case of a last-minute stay of execution that would be vacated only few days or few hours later.[105]

text: Distribution of sentences[edit]

text: Within the context of the overall murder rate, the death penalty cannot be said to be widely or routinely used in the United States; in recent years the average has been about one death sentence for every 200 murder convictions.

text: Alabama has the highest per capita rate of death sentences. This is because Alabama was one of the few states that allowed judges to override a jury recommendation in favor of life imprisonment, a possibility it removed in March 2017.[106][107]

text: Among states[edit]

text: The distribution of death sentences among states is loosely proportional to their populations and murder rates. California, which is the most populous state, has also the largest death row with over 700 inmates. Wyoming, which is the least populous state, has only one condemned man.

text: But executions are more frequent (and happen more quickly after sentencing) in conservative states. Texas, which is the second most populous state of the Union, carried out over 500 executions during the post-Furman era, more than a third of the national total. California has carried out only 13 executions during the same period, and has carried out none since 2006.[108][109][110]

text: Among races[edit]

text: African Americans made up 41% of death row inmates while making up only 12.6% of the general population. They have made up 34% of those actually executed since 1976. However, this is an under-representation relative to the proportion of convicted murderers; 52.5% of all homicide offenders between 1980 and 2008 were African Americans.[111] According to a 2003 Amnesty International report, blacks and whites were the victims of murder in almost equal numbers, yet 80% of the people executed since 1977 were convicted of murders involving white victims.[112]

text: Approximately 13.5% of death row inmates are of Hispanic or Latino descent, while they make up 17.4% of the general population.[113]

text: Among sexes[edit]

text: As of October 1, 2016, the Death Penalty Information Center reports that there are only 54 women on death row.  This constitutes 1.86% of the total death row population.  16 women have been executed since 1976,[114] while 1442 men have been executed.[115]  15,391 total confirmed lawful executions have been carried out in the US since 1608, and of these, 575, or 3.6%, were women.  Women account for 1/50 death sentences, 1/67 people on death row, and 1/100 people whose executions are actually carried out.  The states that have executed the most women are California, Texas and Florida. For women, the racial breakdown of those sentenced to death is 21% black, 13% Latina, 2% American Indian, 61% white and 3% Asian.[114]

text: Methods[edit]

text: All 31 states with the death penalty provide lethal injection as the primary method of execution.

text: Some states allow other methods than lethal injection, but only as secondary methods to be used merely at the request of the prisoner or if lethal injection is unavailable.[116][117]

text: Several states continue to use the historical three-drug protocol: an anesthetic, pancuronium bromide a paralytic, and potassium chloride to stop the heart.[118] Eight states have used a single-drug protocol, inflicting only an overdose of a single anesthetic to the prisoner.[118]

text: While some state statutes specify the drugs required, a majority do not, giving more flexibility to corrections officials.[118]

text: Pressures from anti-death penalty activists and shareholders have made it difficult for correctional services to get the chemicals. Hospira, the only U.S. manufacturer of sodium thiopental, stopped making the drug in 2011.[119] In 2016, it was reported that more than 20 U.S. and European drug manufacturers including Pfizer (the owner of Hospira) had taken steps to prevent their drugs from being used for lethal injections.[119][120][121]

text: Since then, some states have used other anesthetics, such as pentobarbital, etomidate,[122] or fast-acting benzodiazepines like midazolam.[123] Many states have since bought lethal injection drugs from foreign furnishers, and most states have made it a criminal offense to reveal the identities of furnishers or execution team members.[119][124] In November 2015, California adopted regulations allowing the state to use its own public compounding pharmacies to make the chemicals.[125]

text: In 2009, Ohio approved the use of an intramuscular injection of 500 mg of hydromorphone (a 333-fold overdose for an opioid-naïve patient of this narcotic analgesic closely related to and five times stronger than morphine; this is the equivalent of an entire 50-ml bottle of Dilaudid HP, the most powerful commercially available form, although the advantage of hydromorphone is its very high solubility allowing for solutions of almost arbitrary concentration; 500 mg of hydromorphone HCl as pure powder can be dissolved in isotonic saline in volumes as small as under 2 cc)[126] and a supratherapeutic dose of midazolam as a backup means of carrying out executions when a suitable vein cannot be found for intravenous injection.[127][128]

text: Lethal injection was held to be a constitutional method of execution by the U.S. Supreme Court in two cases: Baze v. Rees (2008) and Glossip v. Gross (2015).[129][130]

text: Offender-selected methods[edit]

text: In the following states, death row inmates with an execution warrant may choose to be executed by:[116][117]

text:
Electrocution in Alabama, Arkansas, Florida, Kentucky, South Carolina, Tennessee and Virginia.
Gas inhalation in Arizona and California.
Firing squad in Utah.
Hanging in Washington.

text: In five states (Arizona, Arkansas, Kentucky, Tennessee and Utah), the alternative method is offered only to inmates sentenced to death for crimes committed prior to a specified date (usually when the state switched from the earlier method to lethal injection).

text: When an offender chooses to be executed by a means different from the state default method, which is always lethal injection, he/she loses the right to challenge its constitutionality in court. See Stewart v. LaGrand, 526 US 115 (1999).

text: The last executions by methods other than injection are as follows (all chosen by the inmate):

text:
Method
Date
State
Inmate

Electrocution

January 16, 2013

Virginia

Robert Gleason

Firing squad

June 18, 2010

Utah

Ronnie Lee Gardner

Lethal gas

March 3, 1999

Arizona

Walter LaGrand

Hanging

January 25, 1996

Delaware

William Bailey

text: Backup methods[edit]

text: Depending on the state, the following alternative methods are statutorily provided in the event that lethal injection is either found unconstitutional by a court or unavailable for practical reasons:[116][117][131]

text:
Electrocution in Florida, Oklahoma, South Carolina and Tennessee.
Gas inhalation in Alabama, California, Missouri, Oklahoma and Wyoming.
Firing squad in Oklahoma and Utah.
Hanging in New Hampshire.

text: Oklahoma is the only state allowing more than two methods of execution in its statutes, providing lethal injection, nitrogen hypoxia, electrocution and firing squad to be used in that order in the event that all earlier methods are unavailable. The nitrogen option was added by the Oklahoma Legislature in 2015 and has never been used in a judicial execution, though it is routinely used to give a painless death in animal euthanasia.[132]

text: Three states (Oklahoma, Tennessee and Utah) have added back-up methods recently in 2014 or 2015 (or have expanded their application fields) in reaction to the shortage of lethal injection drugs.[133]

text: Some states such as Florida have a larger provision dealing with execution methods unavailability, requiring their state departments of corrections to use "any constitutional method" if both lethal injection and electrocution are found unconstitutional. This was designed to make unnecessary any further legislative intervention in that event, but the provision applies only to legal (not practical) infeasibility.[134][135]

text: In May 2016, an Oklahoma grand jury recommended the state to use nitrogen hypoxia as its primary method of execution rather than as a mere backup, after experts testified that the method would be painless, easy and "inexpensive".[136]

text: Federal executions[edit]

text: The method of execution of federal prisoners for offenses under the Violent Crime Control and Law Enforcement Act of 1994 is that of the state in which the conviction took place. If the state has no death penalty, the judge must choose a state with the death penalty for carrying out the execution.

text: The federal government has a facility (at U.S. Penitentiary Terre Haute) and regulations only for executions by lethal injection, but the United States Code allows U.S. Marshals to use state facilities and employees for federal executions.[137][138]

text: Execution attendance[edit]

text: The last public execution in the U.S. was that of Rainey Bethea in Owensboro, Kentucky, on August 14, 1936.

text: It was the last execution in the nation at which the general public was permitted to attend without any legally imposed restrictions. "Public execution" is a legal phrase, defined by the laws of various states, and carried out pursuant to a court order. Similar to "public record" or "public meeting", it means that anyone who wants to attend the execution may do so.

text: Around 1890, a political movement developed in the United States to mandate private executions. Several states enacted laws which required executions to be conducted within a "wall" or "enclosure", or to "exclude public view". Most states laws currently use such explicit wording to prohibit public executions, while others do so only implicitly by enumerating the only authorized witnesses.[139]

text:
All states allow news reporters to be execution witnesses for information of the general public, except Wyoming which allow only witnesses authorized by the condemned.[140][141][142]
Several states also allow victims' families and relatives selected by the prisoner to watch executions. An hour or two before the execution, the condemned is offered religious services and to choose his last meal (except in Texas which abolished it in 2011).

text: The execution of Timothy McVeigh on June 11, 2001, was witnessed by over 200 people, most by closed-circuit television.

text: Public opinion[edit]

text: Gallup, Inc. monitors support for the death penalty in the United States since 1937 by asking "Are you in favor of the death penalty for a person convicted of murder?" Gallup surveys document a sharp increase in support for capital punishment between 1966 and 1994 clearly in response to rising violent crime rates during this period (e.g. Page and Shapiro 1992.) However, with the dramatic surge in arguments questioning the fairness of the sentence (due, in part, to DNA exonerations of death row inmates in the national media in the late 1990s (Baumgartner, De Boef, and Boydstun 2004 The Decline of the Death Penalty and the Discovery of Innocence ),[143] support then began to wane, falling from 80% in 1994 to 66% in 2000. Moreover, approval varies substantially depending on the characteristics of the target and the alternatives posed, with much lower support for putting juveniles and the mentally ill to death (26% and 19%, respectively, in 2002) and for the alternative of life imprisonment without the possibility of parole (52% in 2003) Gallup 2005). Given the fact that attitudes toward this policy are often responsive to events, to characteristics of the target, and to alternatives, the conventional wisdom—that death penalty attitudes are impervious to change—is surely overstated. Accordingly, any analysis of death penalty attitudes must account for the responsiveness of such attitudes, as well as their reputed resistance to change[144]

text: In the October 2016 Gallup poll, 60% of respondents said they were in favor and 37% were opposed.[145]

text: Pew Research polls have demonstrated declining American support for the death penalty: 80% in 1974, 78% in 1996, 55% in 2014, and 49% in 2016.[146][147] The 2014 poll showed significant differences by race: 63% of whites, 40% of Hispanics, and 36% of blacks, respectively, supported the death penalty in that year.

text: However in 2018 Polls showed Public support for the death penalty increased up to 54% up from 49%. Since 2016, opinions among Republicans and Democrats have changed little, but the share of independents favoring the death penalty has increased 8 percentage points (from 44% to 52%).[148]

text: A 2010 poll found that 61% of voters would choose a penalty other than the death sentence for murder.[149] When persons surveyed are given a choice between the death penalty and life without parole for persons convicted of capital crimes, support for execution has traditionally been significantly lower than in polling that asks only if a person does or does not support the death penalty. In 2010, for instance, a Gallup poll that offered a choice showed 49% favoring the death penalty, and 46% favoring life imprisonment.[150]

text: On the other hand, in November 2009, another Gallup poll found that 77% of Americans say that September 11 attacks' mastermind Khalid Sheikh Mohammed should get the death penalty if convicted, including 12 who normally opposed the death penalty when asked the 1937 question.[151] A similar result was found in 2001 when respondents were polled about the execution of Timothy McVeigh for the Oklahoma City Bombing that killed 168 victims.[152]

text: Debate[edit]

text: Capital punishment is a controversial issue, with many prominent organizations and individuals participating in the debate. Amnesty International and other groups oppose capital punishment on moral grounds.

text: Some law enforcement organizations, and some victims' rights groups support capital punishment.

text: The United States is one of the four developed countries that still practice capital punishment, along with Japan, Singapore, and Taiwan.

text: Religious groups are widely split on the issue of capital punishment.[153] The Fiqh Council of North America, a group of highly influential Muslim scholars in the United States, has issued a fatwa calling for a moratorium on capital punishment in the United States until various preconditions in the legal system are met.[154]

text: In October 2009, the American Law Institute voted to disavow the framework for capital punishment that it had created in 1962, as part of the Model Penal Code, "in light of the current intractable institutional and structural obstacles to ensuring a minimally adequate system for administering capital punishment". A study commissioned by the institute had said that experience had proved that the goal of individualized decisions about who should be executed and the goal of systemic fairness for minorities and others could not be reconciled.[155] As of  2017[update], 159 prisoners have been exonerated due to evidence of their innocence.[149][156][8]

text: Advocates of the death penalty say that it deters crime, is a good tool for prosecutors in plea bargaining,[157] improves the community by eliminating recidivism by executed criminals, provides "closure" to surviving victims or loved ones, and is a just penalty.

text: The murder rate is highest in the South (6.5 per 100,000 in 2016), where 80% of executions are carried out, and lowest in the Northeast (3.5 per 100,000), with less than 1% of executions. A report by the US National Research Council in 2012 stated that studies claiming a deterrent effect are "fundamentally flawed" and should not be used for policy decisions.[149]

text: According to a survey of the former and present presidents of the country's top academic criminological societies, 88% of these experts rejected the notion that the death penalty acts as a deterrent to murder.

text: Data shows that the application of the death penalty is strongly influenced by racial bias.[149] Furthermore, some opponents argue that it is applied in an arbitrary manner by a criminal justice system that has been shown to be biased through the systemic influence of socio-economic, geographic, and gender factors.[158] Another argument in the capital punishment debate is the cost.[159][149]

text: Various commentators predicted that the death penalty would likely have disappeared in the United States if Hillary Clinton had been elected U.S. President in November 2016 and allowed to appoint a liberal Supreme Court Justice to replace the late Antonin Scalia. Because Donald Trump won and citizens in three states voted the same day for ballot measures supporting capital punishment, columnists came to the conclusion that it will remain indefinitely.[160][161][162]

text: Botched executions[edit]

text: One of the main arguments against the use of capital punishment in the United States is that there has been a long history of botched executions. University of Colorado Boulder Professor Michael L. Radelet described a "botched execution" as an execution that causes the prisoner to suffer for a long period of time before they die.[163] This has led to citizens having the opinion that capital punishment is cruel and unusual punishment. The following is a short list of examples of botched executions that have occurred in the United States.

text:
William Kemmler was the first person executed in the electric chair in 1890. After being pronounced dead after 17 seconds, he was found to be still alive. A second current was passed through him, which was successful. The execution took 2 minutes.[164]
In Arizona, it took Joseph Wood 2 hours to die after being injected.[165]
In Alabama, the execution of Doyle Hamm was cancelled after the prison medical staff had failed to find a vein to insert the lethal injection needle. They attempted for 2 and a half hours and punctured Hamm's skin at least 10 times.[166]
In Florida, Jesse Joseph Tafero had flames burst from his hair during an electrocution.[167]
Wallace Wilkerson died after 27 minutes in pain after the firing squad failed to shoot him in the heart.[168] Because of this, the constitutionality of the use of the firing squad was questioned. The Supreme Court of the United States affirmed that the firing squad did not violate the 8th Amendment in the case Wilkerson v. Utah (1879).[169]
In New Mexico, Thomas Ketchum was decapitated when his body fell through the trap door during his hanging.[170]
In Mississippi, Jimmy Lee Gray died after being in the gas chamber for 9 minutes. During the procedure, Gray thrashed and banged his head against the metal pole behind his head while struggling to breathe.[171]

text: Clemency and commutations[edit]

text: The largest number of clemencies was granted in January 2003 in Illinois when outgoing Governor George Ryan, who had already imposed a moratorium on executions, pardoned four death-row inmates and commuted the sentences of the remaining 167 to life in prison without the possibility of parole.[172] When Governor Pat Quinn signed legislation abolishing the death penalty in Illinois in March 2011, he commuted the sentences of the fifteen inmates on death row to life imprisonment.[35]

text: Previous post-Furman mass clemencies took place in 1986 in New Mexico, when Governor Toney Anaya commuted all death sentences because of his personal opposition to the death penalty. In 1991, outgoing Ohio Governor Dick Celeste commuted the sentences of eight prisoners, among them all four women on the state's death row. And during his two terms (1979-1987) as Florida's Governor, Bob Graham, although a strong death penalty supporter who had overseen the first post-Furman involuntary execution as well as 15 others, agreed to commute the sentences of six people on the grounds of doubts about guilt or disproportionality.

text: Execution hiatus[edit]

text: All executions were suspended through the country between September 2007 and April 2008. At that time, the U.S. Supreme Court was examining the constitutionality of lethal injection in Baze v. Rees. This was the longest period with no executions in the United States since 1982. The Supreme Court ultimately upheld this method in a 7–2 ruling.

text: In addition to the states that have no valid death penalty statute, the following states and jurisdictions are noted that have an official moratorium, or have had no executions for more than ten years, as of 2018:

text:
State / Jurisdiction

Status

Hiatus status[173]

Federal

de facto

No executions since 2003

Military

de facto

No executions since 1961

Arizona

by Attorney General

In 2014, Attorney General indefinitely stayed executions

California

de facto

No executions since 2006[174]

Colorado

by Governor

In 2013, Governor set a moratorium

Kentucky

by court order

In 2009, a federal judge suspended executions pending a new protocol[175]

Montana

by court order

In 2015, a federal judge ruled the state's lethal injection protocol is unlawful, stopping executions[176]

Nebraska

de facto

No executions since 1997

Nevada

de facto

No executions since  2006

North Carolina

by implementers

executions are suspended following a decision by the state's medical board that physicians cannot participate in executions, which is a requirement under state law.

Oklahoma

by implementers

In 2014, state Dept. of Corrections recommended an indefinite hold on executions after a botched execution

Oregon

by Governor

In 2011, Governor announced a moratorium and a review

Pennsylvania

by Governor

In 2015, Governor announced a moratorium pending review

Washington

by Governor

In 2014, Governor announced a moratorium and reprieve for new cases

Wyoming

de facto

No executions since 1992

text: In addition to the above, Kansas (last execution 1965) and New Hampshire (last execution 1939) have also had no executions for over ten years, but in these states it is because of the lack of death row inmates having exhausted the appeal process.

text: Since 1976, four states have executed only condemned prisoners who voluntarily waived further appeals: Pennsylvania has executed three inmates, Oregon two, Connecticut one, and New Mexico one.

text: In North Carolina, executions are suspended following a decision by the state's medical board that physicians cannot participate in executions, which is a requirement under state law.

text: In California, United States District Judge Jeremy Fogel suspended all executions in the state on December 15, 2006, ruling that the implementation used in California was unconstitutional but that it could be fixed.[177]

text: On November 25, 2009, the Kentucky Supreme Court suspended executions until the state adopts regulations for carrying out the penalty by lethal injection.[178]

text: In November 2011, Oregon Governor John Kitzhaber announced a moratorium on executions in Oregon, canceling a planned execution and ordering a review of the death penalty system in the state.[179]

text: On February 11, 2014, Washington Governor Jay Inslee announced a capital punishment moratorium. All death penalty cases that come to Inslee will result in him issuing a reprieve, not a pardon or commutation.[180]

text: On February 13, 2015, Pennsylvania Governor Tom Wolf announced a moratorium on the death penalty. Wolf will issue a reprieve for every execution until a commission on capital punishment, which was established in 2011 by the Pennsylvania State Senate, produces a recommendation.[181] Effectively there was a moratorium in place, as the state had not executed anyone since Gary M. Heidnik in 1999.


document_title: Behavioral communication

question_text: describe four different aggressive behaviors that should not be used in professional communication

root

text: Behavioral communication

text: Different types of communication behavior[edit]

text: There are four different types of communication behavior: aggressive, assertive, passive, and passive-aggressive.

tag: p

text: Aggressive[edit]

text: Aggression is defined as an unplanned act of anger in which the aggressor intends to hurt someone or something.[4] Aggressive communicators typically create avoidable conflict by engaging in personal attacks and put-downs.[5] Aggressive communicators create a win-lose situation and use intimidation to get their own needs met, often at the expense of others.[6] Aggressive communicators typically feel a strong sense of inadequacy, have a lack of empathy, and believe the only way to get their needs met is through power and control.[6] Aggressive communicators are usually close-minded, are poor listeners, and tend to monopolize others.[3]

text: Behaviors often seen during aggressive communication include: putting others down, overpowering others, not showing appreciation, rushing others unnecessarily, ignoring others, not considering other’s feelings, intimidating others, and speaking in a condescending manner.[3][7] Nonverbal behaviors exhibited during aggressive communication include: frowning, critical glares, rigid posture, trying to stand over others, using a loud voice and fast speech.[3]

text: While engaging in this type of communications, individuals typically feel anger, superiority, frustration, and impatience.[3] Aggressive communication often results in counter aggression, alienation, and the creation of resistance or defiance.[3] Additionally, individuals on the receiving end of aggressive communication typically feel: resentful, defensive, humiliated, hurt, and or afraid.[8]

text: There are times when aggressive communication is pertinent, however. The aggressive communication style is essential during emergencies or when decisions have to be quickly made.[3]

text: Assertive[edit]

text: Assertiveness is described as the ability to appropriately expresses one’s own wants and feelings.[7] Assertive communication is thought to be the halfway point between passive communication and aggressive communication.[7] Assertive communication is based on the belief that each individual is responsible for his or her own problems; therefore they are responsible for directly communicating these problems to the other party involved.[6] Assertive communication is a direct form of communication that respects both the communicator’s and the receiver’s rights and opinions.[6] Assertive communication is direct without being argumentative.[6] Engaging in assertive communication helps individuals avoid conflict, maintain relationships, and usually ends in a win-win situation.[9] Assertive communication is the communication style that is least utilized, however.[8]

text: Individuals who engage in assertive communication are open to hearing the opinions of others, without criticizing their opinions, and feel comfortable enough to express their own opinions as well.[6] Assertive communicators generally have high self-esteem, as they have the confidence to effectively communicate with others without getting offended or being manipulative.[8] While engaging in conversation, assertive communicators will state limits and expectations, state observations without judgment, be an active listener, and check on others feelings.[3] Essential problem solving skills that assertive communicators acquire include negotiations, confronting problems as soon as they arise, and not letting negative feelings build up.[3]

text: Behaviors that may be present when an individual is engaging in assertive communication include: being open when expressing their thoughts and feelings, encouraging others to openly express their own opinions and feelings, listening to other’s opinions and appropriately responding to them, accepting responsibilities, being action-orientated, being able to admit mistakes, setting realistic goal, maintaining self-control, and acting as an equal to those whom are on the receiving end of the communication,.[7][3]

text: There are many nonverbal behaviors that represent assertive communication as well. Individuals engaging in assertive communication convey an open and receptive body language, with upright posture and movements that are relaxed.[6] Assertive communicators have a clear tone of voice and make appropriate eye contact.[6] Assertive communicators typically feel more confident and self-respecting while engaging in this type of communication.[7] People on the receiving end of assertive communication typically feel as though they can believe the communicator, know where they stand with the communicator, and possess a sense of respect for the communicator.[8]

text: Assertive communication has positive effects on both the communicator and the receiver. Some positive effects include: the communicator feels connected to others, the communicator feels in control of their lives, the communicator is able to mature because they address and solve issues as they come up, and creating a respectful environment for others.[10]

text: Passive[edit]

text: Passive communication involves not expressing one’s own thoughts or feelings and putting their needs last in an attempt to keep others happy.[9] Passive communicators will internalize their discomfort in order to avoid conflict and to be liked by others.[6] This communication style is typically exhibited when individuals feel as if their needs do not matter and that if they voice their concerns they will be rejected.[6] Individuals who exhibit a predominately passive communication style usually have low self-esteem and may not be able to effectively recognize their own needs.[6] They tend to trust others but they do not trust themselves.[3]

text: There are many behavioral characteristics identified with this communication style. These behavioral characteristics include, but are not limited to: actively avoiding confrontation, difficulty taking responsibilities or making decisions, agreeing with someone else’s preferences, refusing compliments, sighing a lot, asking permission unnecessarily, and blaming others.[8] There are also many non-verbal behaviors that reflect passive communication. Typically, individuals engaging in a passive communication style have a soft voice, speak hesitantly, and make themselves very small.[8] They also tend to fidget and avoid eye contact.[8]

text: Passive communicators elicit numerous feelings in themselves as well as in others. They typically possess feelings of anxiety, depression, resentfulness, feelings of powerlessness, and confusion.[10] They feel anxious because their life seems to be out of their control and they acquire depressive feelings from a perceived sense of hopelessness.[10] Passive communicators may become resentful because they feel as if their own needs are not being met and may become confused because they cannot identify their own feelings.[10] People on the receiving end of passive communication typically feel frustrated, guilty, and may discount the passive communicator for not knowing what they want.[8] While engaging in this type of communication, passive individuals typically feel anxious during the conversation and hurt or angry later.[8]

text: Passive communicators tend to build dependency relationships, often do not know where they stand in situations, and will over-promote others, all resulting in depletion of their self-esteem.[3] Passive communicators do not regularly respond to hurtful situations, but instead let their discomfort build until they have an explosive outburst.[10] This outburst causes shame and confusion, leading the individual back into a passive communication style.[10]

text: There are, however, numerous instances in which passive communication is necessary. A few situations may include: when an issue is minor, when the problems caused by the conflict are worse than the actual conflict, and when emotions are running high.[3]

text: Passive-Aggressive[edit]

text: The Passive-Aggressive style incorporates aspects of both passive and aggressive communication styles. Individuals utilizing this style appear passive, but act out their anger in indirect ways.[8] People who develop this style of communication usually feel powerless, resentful, and or stuck.[10] A passive-aggressive individual exposes their anger through means of procrastination, being exaggeratedly forgetful, and or being intentionally inefficient, among other things.[6]

text: There are many behavioral characteristics that are identified with this communication style. These behavioral characteristics include, but are not limited to: sarcasm, being unreliable, frequent complaining, sulking, patronizing, and gossiping.[8] Non-verbal behaviors, such as posture or facial expression, can also reflect passive-aggressive communication.

text: Typically, individuals engaging in passive-aggressive communication have asymmetrical posture and display jerky or quick gestures.[8] They may also have an innocent facial expression and act excessively friendly to conceal their anger or frustration.[8] People on the receiving end of passive-aggressive communication are usually left confused, angry, and hurt.[8] They tend to be alienated from others because they elicit these unpleasant feelings.[10] A passive-aggressive communication style does not address and properly deal with the pertinent issues or problems. This maladaptive problem-solving style keeps passive-aggressive communicators in a state of powerlessness, resulting in continued passive-aggression.[10]

text: Examples of Passive-Aggressive Language/Behavior include: wistful statements, backhanded compliments, purposefully ignoring or saying nothing, leaving someone out, sabotaging someone, and muttering to oneself instead of confronting the issue.[11]


document_title: List of tallest players in National Basketball Association history

question_text: who is currently the tallest player in the nba 2018

text: This is a list of the tallest players in National Basketball Association history. Twenty five of them have been listed at 7 feet, 3 inches or taller. Two are active as of the 2017–18 season; Kristaps Porziņģis of the New York Knicks and Boban Marjanović of the Los Angeles Clippers. The tallest player inducted into the Naismith Memorial Basketball Hall of Fame is 7 feet, 6 inch Yao Ming. In addition to Yao, Ralph Sampson and Arvydas Sabonis were the only other players 7'3" or taller selected to the Hall of Fame.

text: In the seventh round of the 1981 NBA Draft, the Golden State Warriors used the 171st pick to select Yasutaka Okayama, a Japanese basketball player who was measured at 7 feet 8 inches (2.34 m) and 330 pounds (150 kg).[1][2] Okayama, who attended and played junior varsity basketball at the University of Portland for one and a half years in 1976 as an exchange student, declined to try out for the Warriors and never played in the NBA.[3] He is the tallest person ever drafted and would have been the tallest player in the NBA had he played in the league.[4]

text:
^
Active NBA player

*
Inducted into the Naismith Memorial Basketball Hall of Fame

GP
Games played
Pts
Points
PPG
Points per game

FG%
Field goal percentage
FT%
Free throw percentage
Reb
Rebounds

RPG
Rebounds per game
Blk
Blocks
BPG
Blocks per game

tag: table

text:
Height
Weight
Player
Nationality
Teams
GP
Pts
PPG
FG%
FT%
Reb
RPG
Blk
BPG
Notes

7 ft 7 in (2.31 m)
315 lb (143 kg)
Mureșan, GheorgheGheorghe Mureșan
 Romania
Washington Bullets (1993–1997)
New Jersey Nets (1998–2000)
307
3,020
9.8
.573
.644
1,957
6.4
455
1.5
Generally considered slightly taller than Manute Bol. Bol was officially measured at 7 feet, 6 3/4 inches tall by the Guinness Book of World Records.

7 ft 6.75 in (2.31 m)
200 lb (91 kg)
Bol, ManuteManute Bol
 Sudan
Washington Bullets (1985–1988, 1994)
Golden State Warriors (1988–1990, 1994)
Philadelphia 76ers (1990–1993, 1994)
Miami Heat (1994)
624
1,599
2.6
.407
.561
2,647
4.2
2,086
3.3
Played alongside the shortest player in NBA history, Muggsy Bogues, during the 1987–88 season for the Washington Bullets; their difference in height was 28 inches. Only player in NBA history to have more blocked shots than points scored in his career. Weighed just 195 pounds (89 kg)[citation needed] when he entered the league in 1985.

7 ft 6 in (2.29 m)
275 lb (125 kg)
Bradley, ShawnShawn Bradley
 U.S.
 Germany
Philadelphia 76ers (1993–1995)
New Jersey Nets (1995–1997)
Dallas Mavericks (1997–2005)
832
6,752
8.1
.457
.716
5,268
6.3
2,119
2.5
Born to American parents in the former West Germany.

7 ft 6 in (2.29 m)
310 lb (141 kg)
Yao Ming, Yao Ming*
 China
Houston Rockets (2002–2011)
481
9,196
19.1
.525
.832
4,467
9.3
912
1.9
Tallest player to play in at least one All-Star Game. Also tallest player inducted into the Hall of Fame.

7 ft 5 in (2.26 m)
359 lb (163 kg)
Bhullar, SimSim Bhullar
 Canada
Sacramento Kings (2015)
3
2
0.7
.500
—
1
0.3
1
0.3
First NBA player of Indian descent. Played 16 seconds in his debut on April 7, 2015.

7 ft 5 in (2.26 m)
250 lb (113 kg)
Nevitt, ChuckChuck Nevitt
 United States
Houston Rockets (1982–1983, 1988–1990)
Los Angeles Lakers (1984–1985)
Detroit Pistons (1985–1988)
Chicago Bulls (1991)
San Antonio Spurs (1993)
155
251
1.6
.438
.589
239
1.5
111
0.7
Tallest player to win an NBA Championship.

7 ft 5 in (2.26 m)
305 lb (138 kg)
Podkolzin, PavelPavel Podkolzin
 Russia
Dallas Mavericks (2004–2006)
6
4
0.7
.000
.500
9
1.5
1
0.1

7 ft 5 in (2.26 m)
294 lb (133 kg)
Vraneš, SlavkoSlavko Vraneš
 Montenegro
Portland Trail Blazers (2004)
1
0
0.0
.000
—
0
0.0
0
0.0
Played in one game, on 000000002004-01-08-0000January 8, 2004 against the Minnesota Timberwolves. Played 3 minutes, with one shot attempt from the field (missed) and one personal foul. Vraneš was officially listed as 7'5" while playing in the NBA, and has since grown taller (7'6" or 2.30 m), according to most sources.

7 ft 4 in (2.24 m)
290 lb (132 kg)
Eaton, MarkMark Eaton
 United States
Utah Jazz (1982–1993)
875
5,216
6.0
.458
.649
6,939
7.9
3,064
3.5
He set records for most blocked shots per game in a single season (5.56 bpg in 1984–85) and for an entire career (3.50 bpg) - both marks still stand today.

7 ft 4 in (2.24 m)
250 lb (113 kg)
Smits, RikRik Smits
 Netherlands
Indiana Pacers (1988–2000)
867
12,871
14.8
.507
.773
5,277
6.1
1,111
1.3

7 ft 4 in (2.24 m)
235 lb (107 kg)
Sampson, RalphRalph Sampson*
 United States
Houston Rockets (1983–1987)
Golden State Warriors (1987–1989)
Sacramento Kings (1989–1991)
Washington Bullets (1991–1992)
456
7,039
15.4
.486
.661
4,011
8.8
752
1.6

7 ft 4 in (2.24 m)
325 lb (147 kg)
Lauderdale, PriestPriest Lauderdale
 United States
Atlanta Hawks (1996–1997)
Denver Nuggets (1997–1998)
74
255
3.4
.472
.554
143
1.9
26
0.4

7 ft 3.5 in (2.22 m)
293 lb (133 kg)
Marjanović, BobanBoban Marjanović^
 Serbia
San Antonio Spurs (2015–2016)
Detroit Pistons (2016–2018)
Los Angeles Clippers (2018–present)
89
488
5.5
.578
.779
324
3.6
35
0.4

7 ft 3.5 in (2.22 m)
290 lb (132 kg)
Ramos, Peter JohnPeter John Ramos
 Puerto Rico
Washington Wizards (2004–2005)
6
11
1.8
.500
.500
4
0.7
1
0.2

7 ft 3 in (2.21 m)
263 lb (119 kg)
Breuer, RandyRandy Breuer
 United States
Milwaukee Bucks (1983–1990)
Minnesota Timberwolves (1990–1992)
Atlanta Hawks (1992–1993)
Sacramento Kings (1993)
681
4,599
6.8
.467
.628
2,986
4.4
750
1.1

7 ft 3 in (2.21 m)
212 lb (96 kg)
Closs, KeithKeith Closs
 United States
Los Angeles Clippers (1997–2000)
130
502
3.9
.471
.606
372
2.9
163
1.3
During his collegiate career, Closs averaged 5.9 blocks per game, which is the NCAA Division I record.

7 ft 3 in (2.21 m)
235 lb (107 kg)
Halbrook, SwedeSwede Halbrook
 United States
Syracuse Nationals (1960–1962)
143
786
5.5
.347
.591
949
6.6
—
—

7 ft 3 in (2.21 m)
260 lb (118 kg)
Ilgauskas, ŽydrūnasŽydrūnas Ilgauskas
 Lithuania
Cleveland Cavaliers (1997–2010)
Miami Heat (2010–2011)
771
10,616
13.8
.475
.780
5,904
7.7
1,269
1.6

7 ft 3 in (2.21 m)
250 lb (113 kg)
Radojević, AleksandarAleksandar Radojević
 Bosnia & Herzegovina
 Montenegro
Toronto Raptors (1999–2000)
Utah Jazz (2004–2005)
15
26
1.7
.308
.625
36
2.4
3
0.2

7 ft 3 in (2.21 m)
292 lb (132 kg)
Sabonis, ArvydasArvydas Sabonis*
 Lithuania
Portland Trail Blazers (1995–2001, 2002–2003)
470
5,629
12.0
.500
.786
3,436
7.3
494
1.1
Sabonis was originally drafted into the NBA in 1986 (Rd. 1, #24 overall), but he was not allowed to play in the NBA for most of his career due to restrictions by the former Soviet Union.

7 ft 3 in (2.21 m)
305 lb (138 kg)
Seung-Jin, HaHa Seung-Jin
 South Korea
Portland Trail Blazers (2005–2006)
46
70
1.5
.519
.500
67
1.5
13
0.3
Only Korean player to play in the NBA.

7 ft 3 in (2.21 m)
290 lb (132 kg)
Thabeet, HasheemHasheem Thabeet^
 Tanzania
Memphis Grizzlies (2009–2011)
Houston Rockets (2011–2012)
Portland Trail Blazers (2012)
Oklahoma City Thunder (2012–2014)
224
483
2.2
.567
.578
595
2.7
184
0.8
Only Tanzanian player to play in the NBA.

7 ft 3 in (2.21 m)
256 lb (116 kg)
Pleiß, TiborTibor Pleiß
 Germany
Utah Jazz (2015–2016)
12
24
2.0
.440
1.000
15
1.3
2
0.2

7 ft 3 in (2.21 m)
265 lb (120 kg)
Tavares, WalterWalter Tavares
 Cape Verde
Atlanta Hawks (2015–2016)
Cleveland Cavaliers (2017)
13
33
2.5
.625
.273
32
2.5
12
0.9
Only Cape Verdean player to play in the NBA.

7 ft 3 in (2.21 m)
240 lb (109 kg)
Porziņģis, KristapsKristaps Porziņģis^
 Latvia
New York Knicks (2015–Present)
138
2,224
16.1
.436
.811
1001
7.3
263
1.9
Was measured at 7'1" during the NBA Draft Combine, but grew two inches before officially playing for the New York Knicks. Is the tallest winner of the Taco Bell Skills Challenge.


document_title: Equitable remedy

question_text: from what country did equitable remedies as applied in the u.s. grow out

text: Equitable remedy

text: This article may be incomprehensible or very hard to understand. Please help by rewording it if the intended meaning can be determined. The talk page may have details. (June 2017) (Learn how and when to remove this template message)

text: Equitable remedies are judicial remedies developed by courts of equity from about the time of Henry VII to provide more flexible responses to changing social conditions than was possible in precedent-based common law.[1][2]

text:
Judicial remedies
Legal remedies (Damages)
Compensatory damages
Punitive damages
Incidental damages
Consequential damages
Liquidated damages
Reliance damages
Nominal damages
Statutory damages
Treble damages

Equitable remedies
Specific performance
Account of profits
Constructive trust
Injunction
Restitution
Rescission
Rectification
Declaratory relief

Related issues
Adequate remedy
Election of remedies
Provisional remedy
Tracing
Legal costs
vte

text: Equitable remedies were granted by the Court of Chancery in England, and remain available today in most common law jurisdictions. In many jurisdictions, legal and equitable remedies have been merged and a single court can issue either, or both, remedies. Despite widespread judicial merger, the distinction between equitable and legal remedies remains relevant in a number of significant instances. Notably, the United States Constitution's Seventh Amendment preserves the right to a jury trial in civil cases over $20 to cases "at common law".

text: The distinction between types of relief granted by the courts is due to the courts of equity, such as the Court of Chancery in England, and still available today in common law jurisdictions.[3] Equity is said to operate on the conscience of the defendant, so an equitable remedy is always directed at a particular person, and that person's knowledge, state of mind and motives may be relevant to whether a remedy should be granted or not.

text: Equitable remedies are distinguished from "legal" remedies (which are available to a successful claimant as of right) by the discretion of the court to grant them.  In common law jurisdictions, there are a variety of equitable remedies, but the principal remedies are:

text:
injunction[4][5]
specific performance
account of profits
rescission
rectification
equitable estoppel
certain proprietary remedies, such as constructive trusts[6]
subrogation
in very specific circumstances, an equitable lien.[7]
equitable compensation
appointment or removal of fiduciary
interpleader

tag: ol

text: The two main equitable remedies are injunctions and specific performance, and in casual legal parlance references to equitable remedies are often expressed as referring to those two remedies alone.  Injunctions may be mandatory (requiring a person to do something) or prohibitory (stopping them doing something). Specific performance requires a party to perform a contract, for example by transferring a piece of land to the claimant. The award of specific performance requires that the two following criteria must be satisfied:[8] (i) Common law damages must be an inadequate remedy. For instance, when damages for a breach of contract found in favour of a third party are an inadequate remedy.[9] (ii) No bars to equitable relief prevent specific performance. A bar to relief arises for example, when the court's continuous supervision of the defendant is not feasible.[10]

text: An account of profits is usually ordered where payment of damages would still leave the wrongdoer unjustly enriched at the expense of the wronged party. However, orders for an account are not normally available as of right, and only arise in certain circumstances.[11]

text: Rescission and rectification are remedies in relation to contracts (or, exceptionally, deeds) which may become available.

text: Constructive trusts and tracing remedies are usually used where the claimant asserts that property has been wrongly appropriated from them, and then either (i) the property has increased in value, and thus they should have an interest in the increase in value which occurred at their expense, or (ii) the property has been transferred by the wrongdoer to an innocent third party, and the original owner should be able to claim a right to the property as against the innocent third party.

text: Equitable liens normally only arise in very specific factual circumstances, such as unpaid vendor's lien.

text: Equitable principles can also limit the granting of equitable remedies.  This includes "he who comes to equity must come with clean hands" (that is, the court will not assist a claimant who is himself in the wrong or acting for improper motives), laches (equitable remedies will not be granted if the claimant has delayed unduly in seeking them), "equity will not assist a volunteer" (meaning that a person cannot litigate against a settlor without providing the appropriate consideration, for example, Money) and that equitable remedies will not normally be granted where damages would be an adequate remedy.  The most important limitation relating to equitable remedies is that an equitable remedy will not lie against a bona fide purchaser for value without notice.

text: Damages can also be awarded in "equity" as opposed to "at law",[12] and in some legal systems, by historical accident, interest on damages can be awarded on a compound basis only on equitable damages, but not on damages awarded at law.[13]  However, most jurisdictions either have ended this anachronism, or evinced an intention to do so, by modernising legislation. Two versions of the legislation are in force in Australian jurisdiction with one version placing emphasis on "commission of a wrongful act" and the other omits the reference to wrongdoing.[14]

text: The classification of a remedy as equitable has various consequences. For example, equitable remedies may be enforced by contempt,[15] and equitable remedies are subject to equitable defenses.[16]


document_title: Benny the Bull

question_text: who plays benny the bull in real life

question_tokens: who plays benny the bull in real life

text: Benny the Bull

text: Biography / retired versions[edit]

text: Benjamin The "Benny" Bull, has been the mascot of the Chicago Bulls for more than 45 years, first at Chicago Stadium (1969–1994), and now at the United Center (1994–present). He had become just as popular as some of the franchise's most notable figures, such as players Michael Jordan, Scottie Pippen, Dennis Rodman, and head coach Phil Jackson. Benny is one of the longest-tenured mascots in the NBA and in all of professional sports. Benny was named after Ben Bentley, the Bulls first Public Relations Manager and Stadium Announcer. Benny was one of the promotional tools general manager Pat Williams employed to boost the Bulls' arena entertainment and attendance.[2]

text: The current and most popular Benny has had many "relatives" or family members over the years. His great-grandfather, in the late 60s, was the first NBA mascot. Many other variations/family members of the bull where passed on to different ones, including Benny's chubby predecessor (or father) in the 90s. A slim, dunking bull mascot named "Da Bull" was added at the time. According to an article on the Bull's website: "Da Bull is Benny the Bull's cousin, and he made his first appearance at a Bulls game during the 1995–96 season. That is why his uniform number is 95. Among Da Bull's many talents are tumbling, gymnastics, playing basketball, break dancing, reading, officiating basketball games, and most importantly, performing his signature slam dunks. Da Bull does not have a tail like other Bulls. He lost his tail while practicing his amazing dunks at the United Center. By not having a tail, Da Bull has been able to perform even more slam dunks and tumbling because his long, skinny tail no longer gets in the way. An injury to his hoof during the 1999–2000 Bulls season sidelined Da Bull briefly, but he returned to the trampoline after a short recovery period." [3][4] His performer, Chester Brewer, was arrested in 2004 for illegally selling marijuana from his car, therefore retiring the mascot.[5]

text: Current Benny[edit]

text: In 2004, the current version of Benny The Bull was introduced. He has been acclaimed as one of the most popular mascots of all time, including being named the most popular mascot in sports by Forbes in 2013 [6]

text: The modern version of Benny is famous for his impressive dancing, aerobic flips and jumps, multiple dunking tricks, giant popcorn spilling, rappelling from the United Center rafters, shooting backwards halfcourt shots, banging on his drum, using multiple cans of silly string, interacting with crowds, instances of taunting opposing players (most notably his act of tearing off the pants of others' pre-game warm up outfits), driving his bike down stairs, throwing cakes, shooting T-shirts out of his "Bullzooka", and more. He usually performs trampoline dunks alongside his team "Benny and the Elevators" [7] His current "family" consists of two inflatable mascots named "Big Ben" and "Benji".[8] (Benji has a similar appearance to "Lil' Benny", who used to appear alongside Benny on the court and in videos. Lil' Benny's overall design was based on the 1990s Benny) Benny's antics have gotten him worldwide attention and recognition. He's also been seen alongside multiple celebrities, from messing with Justin Bieber or performing the "Single Ladies" dance in front of Jay-Z [9] In addition to performing stunts and entertaining the crowd at Bulls games, Benny also makes public appearances around the Chicago area on behalf of the team. Benny made approximately 250 appearances per year. As a member of the Bulls' All-Star Reading Team, he appeared at schools to promote literacy and the importance of a good education. He could also be booked for private events. Benny had also worked as a mascot on individual dates for other professional sports franchises, such as the Billings Outlaws. He usually travels around in his van, 'Benny's Bull Ride™' and is almost always with his assistant, Todd Abbott.

text: Barry Anderson, after 12 years of taking on the role of Benny, announced that he will be retiring on June 30, 2016, to take on other interests, although Benny won't disappear entirely.[10]

text: The Bulls redesigned the Benny character in 2004 just for him after his impressive talents were awarded twice in the Capital One Mascot Challenge for his previous role, Monte from the University of Montana.[11]

text: Appearance[edit]

text: Benny has bright red fur with large eyes, a tan snout, horns with red tips, orange and pink hair, a long red tail and black gloves with red fur on the back. Benny wears an authentic uniform (road red/black and home whites) and team-appointed athletic shoes. His jersey bore the name "Benny" above the number "1" on the back. From 2004 to modern times, the pupils of his eyes have gotten larger. Benny sports several different costumes based on the theme of the game as well as his overall "mood". His collection consists of a traditional Santa suit, an Latin/salsa suit, a black and a white tuxedo for classy events, a grim reaper hood, multiple plaid jackets, a green version of the regular uniform along with a leprechaun outfit for St. Patrick's day (that also comes with his red fur switched to green, or for a recycling campaign), Elvis Presley garb, and a large amount of other appearances.

text: In other media[edit]

text: Benny was one of the many secret characters featured in the video game NBA Jam Tournament Edition. Along with him, three other NBA mascots appear in the game: the Phoenix Suns Gorilla, Charlotte Hornets' Hugo and Minnesota Timberwolves' Crunch.

text: The late punk musician Wesley Willis did a song about him called "Benny the Bull".


document_title: Will Gardner

question_text: who is will gardner in the good wife

question_tokens: who is will gardner in the good wife

text: Will Gardner

text:
Will Gardner

The Good Wife character

First appearance
"Pilot"
September 22, 2009

Last appearance
"End"
May 8, 2016

Created by
Robert King and Michelle King

Portrayed by
Josh Charles

Information

Gender
Male

Occupation
Attorney at law

Significant other(s)
Alicia Florrick (on and off again)

Relatives
Sarah Gardner (sister)
Audrey Gardner (sister)[1]

text: Will Gardner is a character of CBS television series The Good Wife and was portrayed by Josh Charles for the first five seasons of the show's run.[2] For his performance, Charles received two Primetime Emmy Award nominations as well as a Golden Globe nomination.[3]

text: Background[edit]

text: An old friend of Alicia's, in the pilot he helped her get a job with the firm and is constantly trying to avoid appearing as if he favors her. This is complicated by the fact that the two have feelings for each other. Will and Alicia have an affair beginning at the end of season two.[4] In season three they break up when Alicia's daughter goes missing, and Alicia decides she needs to focus more on her children. He is seen as very much of a ladies' man throughout the series and had various love affairs and girlfriends. Will generally had a good working relationship with Diane Lockhart, his co-managing partner at the firm, and the two demonstrate a shrewd ability to guide their business, even through difficult times. Will plays in a regular pick-up basketball game with other attorneys and judges, and has friendships with the players that are eventually scrutinized. During season three, Will is suspended from practicing law for six months as punishment stemming from an old bribery scandal but returns to the firm in season four. In season five after much planning, Alicia and Cary leave Lockhart & Gardner to start their own firm; Will takes this betrayal personally. In episode 15 of the fifth season, he is shot and killed in the courtroom by his client Jeffrey Grant[2] (played by Hunter Parrish).

text: Following his death, he appeared in dream sequences in episodes "Minds Eye"[5] and the series finale, "End".[6]


document_title: Forbes' list of the most valuable football clubs

question_text: top 10 most supported clubs in the world

text: Current ranking

text: Rankings as of 1 June 2017.[1]

text:
Rank
Team
Country
Value
In millions

Debt as
% of value[2]
% change
on year
Revenue ($M)

1
Manchester United
 England
4,583
6
11
850

2
Barcelona
 Spain
3,635
6
2
688

3
Real Madrid
 Spain
3,580
3
-2
688

4
Bayern Munich
 Germany
2,713
0
1
657

5
Manchester City
 England
2,083
5
8
650

6
Arsenal
 England
1,932
16
-4
572

7
Chelsea
 England
1,845
0
11
583

8
Liverpool
 England
1,492
7
-4
523

9
Juventus
 Italy
1,258
7
-3
379

10
Tottenham Hotspur
 England
1,058
17
4
377

11
Paris Saint-Germain
 France
841
0
3
578

12
Borussia Dortmund
 Germany
808
0
-3
315

13
A.C. Milan
 Italy
802
73
-3
238

14
Atlético Madrid
 Spain
732
9
16
234

15
West Ham United
 England
634
11
17
213

16
Schalke 04
 Germany
629
7
-4
249

17
Roma
 Italy
569
3
-2
242

18
Inter Milan
 Italy
537
37
-4
199

19
Leicester City
 England
413
0
-
191

20
Napoli
 Italy
379
0
-4
158

text: Historical rankings

text: 2016 rankings

text: Rankings as of 1 May 2016.[3]

text:
Rank
Team
Country
Value ($M)[4]
Debt as
% of value[5]
% change
on year
Revenue ($M)

1
Real Madrid
 Spain
3,645
3
12
694

2
Barcelona
 Spain
3,549
2
12
675

3
Manchester United
 England
3,317
20
7
625

4
Bayern Munich
 Germany
2,678
0
14
570

5
Arsenal
 England
2,017
17
54
524

6
Manchester City
 England
1,921
0
40
558

7
Chelsea
 England
1,661
0
21
505

8
Liverpool
 England
1,548
5
58
471

9
Juventus
 Italy
1,299
4
55
390

10
Tottenham Hotspur
 England
1,017
2
69
310

11
Borussia Dortmund
 Germany
836
0
19
338

12
A.C. Milan
 Italy
825
32
6
240

13
Paris Saint-Germain
 France
814
0
28
578

14
Schalke 04
 Germany
655
21
15
264

15
Atlético Madrid
 Spain
633
22
45
225

16
Inter Milan
 Italy
559
43
27
198

17
West Ham United
 England
542
6
76
194

18
Roma
 Italy
508
36
N/A
217

19
Napoli
 Italy
396
0
12
151

20
Newcastle United
 England
383
0
10
104

text: 2015 rankings

text: Rankings as of 6 May 2015.[6]

text:
Rank
Team
Country
Value ($M)[4]
Debt as
% of value[7]
% change
on year
Revenue ($M)

1
Real Madrid
 Spain
3,260
4
-5
746

2
Barcelona
 Spain
3,160
3
-1
657

3
Manchester United
 England
3,100
20
10
703

4
Bayern Munich
 Germany
2,350
0
27
661

5
Manchester City
 England
1,380
0
60
562

6
Chelsea
 England
1,370
0
58
526

7
Arsenal
 England
1,310
30
-2
487

8
Liverpool
 England
982
10
39
415

9
Juventus
 Italy
837
9
-2
379

10
A.C. Milan
 Italy
775
44
-9
339

11
Borussia Dortmund
 Germany
700
6
17
355

12
Paris Saint-Germain
 France
634
0
53
643

13
Tottenham Hotspur
 England
600
9
17
293

14
Schalke 04
 Germany
572
0
-1
290

15
Inter Milan
 Italy
439
56
-9
222

16
Atlético Madrid
 Spain
436
53
33
231

17
Napoli
 Italy
353
0
19
224

18
Newcastle United
 England
349
0
N/A
210

19
West Ham United
 England
309
12
N/A
186

20
Galatasaray
 Turkey
294
17
-15
220

text: 2014 rankings

text: Rankings as of 15 July 2014.[8]

text:
Rank
Team
Country
Value ($M)[4]
% change
on year
Revenue ($M)

1
Real Madrid
 Spain
3,440
4
675

2
Barcelona
 Spain
3,200
23
627

3
Manchester United
 England
2,810
-11
551

4
Bayern Munich
 Germany
1,850
41
561

5
Arsenal
 England
1,331
0
370

6
Chelsea
 England
868
-4
394

7
Manchester City
 England
863
25
411

8
A.C. Milan
 Italy
856
-9
343

9
Juventus
 Italy
850
22
354

10
Liverpool
 England
704
8
313

11
Borussia Dortmund
 Germany
599
31
333

12
Schalke 04
 Germany
580
16
258

13
Tottenham Hotspur
 England
514
-1
224

14
Inter Milan
 Italy
483
20
219

15
Paris Saint-Germain
 France
415
N/A
518

16
Galatasaray
 Turkey
347
N/A
204

17
Atlético Madrid
 Spain
328
33
156

18
Hamburg
 Germany
326
9
176

19
Roma
 Italy
307
19
162

20
Napoli
 Italy
296
-10
156

text: 2013 rankings

text: Rankings as of 17 April 2013.[9]

text:
Rank
Team
Country
Value ($M)[4]
% change
on year
Revenue ($M)

1
Real Madrid
 Spain
3,300
76
650

2
Manchester United
 England
3,165
61
502

3
Barcelona
 Spain
2,600
99
613

4
Arsenal
 England
1,326
3
368

5
Bayern Munich
 Germany
1,309
6
468

6
A.C. Milan
 Italy
945
-4
326

7
Chelsea
 England
901
18
409

8
Juventus
 Italy
694
17
248

9
Manchester City
 England
689
56
362

10
Liverpool
 England
651
5
296

11
Tottenham Hotspur
 England
520
-8
226

12
Schalke 04
 Germany
498
-15
221

13
Borussia Dortmund
 Germany
436
11
240

14
Inter Milan
 Italy
401
-18
236

15
Lyon
 France
368
-4
167

16
Corinthians
 Brazil
358
-
119

17
Napoli
 Italy
330
17
188

18
Hamburg
 Germany
300
-15
154

19
Marseille
 France
285
-18
167

20
Newcastle United
 England
263
9
146

text: 2012 rankings

text: Rankings as of 19 April 2012.[10]

text:
Rank
Team
Country
Value ($M)[4]
% change
on year
Revenue ($M)

1
Manchester United
 England
1,965
5
532

2
Real Madrid
 Spain
1,877
34
695

3
Barcelona
 Spain
1,307
34
653

4
Arsenal
 England
1,292
8
364

5
Bayern Munich
 Germany
1,235
12
466

6
A.C. Milan
 Italy
989
18
341

7
Chelsea
 England
761
16
362

8
Liverpool
 England
619
12
295

9
Juventus
 Italy
591
-6
223

10
Schalke 04
 Germany
587
56
293

11
Tottenham Hotspur
 England
564
37
262

12
Inter Milan
 Italy
490
11
307

13
Manchester City
 England
443
52
246

14
Borussia Dortmund
 Germany
394
52
197

15
Lyon
 France
385
8
193

16
Hamburg
 Germany
355
4
187

17
Roma
 Italy
354
38
208

18
Marseille
 France
349
26
218

19
Valencia
 Spain
288
-
186

20
Napoli
 Italy
283
-
167

text: 2011 rankings

text: Rankings as of 20 April 2011.[11]

text:
Rank
Team
Country
Value ($M)[4]
% change
on year
Revenue ($M)

1
Manchester United
 England
1,864
1
428

2
Real Madrid
 Spain
1,400
10
537

3
Arsenal
 England
1,200
1
336

4
Bayern Munich
 Germany
1,100
6
396

5
Barcelona
 Spain
975
-2
488

6
A.C. Milan
 Italy
838
5
289

7
Chelsea
 England
658
2
313

8
Juventus
 Italy
628
-4
251

9
Liverpool
 England
552
-33
276

10
Inter Milan
 Italy
441
7
275

11
Tottenham Hotspur
 England
412
11
179

12
Schalke
 Germany
377
-2
171

13
Lyon
 France
358
8
179

14
Hamburg
 Germany
340
3
179

15
Manchester City
 England
291
13
153

16
Stuttgart
 Germany
281
0
141

17
Werder Bremen
 Germany
279
2
147

18
Marseille
 France
277
6
173

19
Atlético Madrid
 Spain
275
6
153

20
Borussia Dortmund
 Germany
260
-1
124

text: 2010 rankings

text: Rankings as of April 2010.[12][13]

text:
Rank
Team
Country
Value ($M)[4]
Debt as
% of value[14]
% change
on year
Revenue ($M)
Operating
income ($m)[15]

1
Manchester United
 England
1,835
46
-2
459
150

2
Real Madrid
 Spain
1,323
54
-2
563
130

3
Arsenal
 England
1,181
41
-2
369
102

4
Barcelona
 Spain
1,000
58
4
513
113

5
Bayern Munich
 Germany
990
14
-11
406
61

6
Liverpool
 England
822
47
-19
304
37

7
A.C. Milan
 Italy
800
0
-19
276
41

8
Juventus
 Italy
656
3
9
285
57

9
Chelsea
 England
646
8
-19
340
-73

10
Inter Milan
 Italy
413
0
12
276
-14

11
Schalke
 Germany
384
50
-25
175
-7

12
Tottenham Hotspur
 England
372
29
-16
186
35

13
Lyon
 France
333
10
-21
196
5

14
Hamburg
 Germany
329
0
0
206
41

15
Roma
 Italy
308
0
-19
205
25

16
Werder Bremen
 Germany
274
0
-6
161
24

17
Marseille
 France
262
0
9
187
19

18
Borussia Dortmund
 Germany
261
32
-20
145
8

19
Manchester City
 England
258
0
-17
143
-56

20
Newcastle United
 England
198
8
-30
142
-49

text: 2009 rankings

text: Rankings as of April 2009.[16]

text:
Rank
Team
Country
Value ($M)[4]
Debt as
% of value[14]
% change
on year
Revenue ($M)
Operating
income ($m)[15]

1
Manchester United
 England
1,870
54
4
512
160

2
Real Madrid
 Spain
1,353
23
5
576
81

3
Arsenal
 England
1,200
107
0
349
80

4
Bayern Munich
 Germany
1,110
0
21
465
59

5
Liverpool
 England
1,010
59
-4
332
50

6
A.C. Milan
 Italy
990
0
24
330
58

7
Barcelona
 Spain
960
43
22
487
108

8
Chelsea
 England
800
92
5
424
-13

9
Juventus
 Italy
600
5
18
264
46

10
Schalke
 Germany
510
38
9
234
41

11
Tottenham Hotspur
 England
445
29
12
228
70

12
Lyon
 France
423
18
4
245
94

13
Roma
 Italy
381
9
-12
276
69

14
Inter Milan
 Italy
370
77
-8
272
27

15
Hamburg
 Germany
330
0
13
202
44

16
Borussia Dortmund
 Germany
325
33
1
183
9

17
Manchester City
 England
310
0
62
164
-16

18
Werder Bremen
 Germany
292
0
12
177
27

19
Newcastle United
 England
285
96
-5
198
-13

20
Stuttgart
 Germany
264
0
not reported
176
18

21
Aston Villa
 England
240
10
26
150
1

21
Marseille
 France
240
0
28
200
20

23
Celtic
 Scotland
218
14
-4
145
11

24
Everton
 England
207
49
5
151
14

25
Rangers
 Scotland
194
86
not reported
128
15

text: 2008 rankings

text: This is the April 2008 list.[17]

text:
Rank
Team
Country
Value ($M)[4]
Debt as
%of value[14]
% change
on year
Revenue ($M)
Operating
income($m)[15]

1
Manchester United
 England
1,800
60
24
394
111

2
Real Madrid
 Spain
1,285
27
24
474
112

3
Arsenal
 England
1,200
43
31
329
77

4
Liverpool
 England
1,050
65
131
269
60

5
Bayern Munich
 Germany
917
0
9
302
72

6
A.C. Milan
 Italy
798
0
-3
307
54

7
Barcelona
 Spain
784
27
47
392
92

8
Chelsea
 England
764
0
42
382
-5

9
Juventus
 Italy
510
5
-10
196
35

10
Schalke
 Germany
470
48
0
154
36

11
Roma
 Italy
434
12
94
213
48

12
Tottenham Hotspur
 England
414
15
70
207
64

13
Lyon
 France
408
7
19
190
15

14
Inter Milan
 Italy
403
0
-27
207
21

15
Borussia Dortmund
 Germany
323
57
63
122
31

16
Newcastle United
 England
300
43
16
175
12

17
Hamburg
 Germany
293
0
32
163
41

18
Werder Bremen
 Germany
262
0
n/a
131
11

19
Valencia
 Spain
254
159
31
145
-45

20
Celtic
 Scotland
227
11
23
151
48

21
Everton
 England
197
30
24
103
-1

22
West Ham United
 England
195
23
25
115
-22

23
Manchester City
 England
191
63
-8
114
27

24
Aston Villa
 England
190
12
36
106
-40

25
Marseille
 France
187
0
19
134
13

text: Manchester United increased from $1.2 billion to $1.8 billion still remaining at top. While Real Madrid remains second due to an increase of $400 million. Arsenal also remain third after an approximate increase of $350 million.

tag: ul

text: 2007 rankings

text: This is the list released in March 2007.

text:
#
Team
Country
Value ($M)[4]
Debt as
%of value[14]
% change
on year
Revenue ($M)
Operating
income($m)[15]

1
Manchester United
 England
1,453
84
6
310
92

2
Real Madrid
 Spain
1,036
10
2
000
83

3
Arsenal
 England
915
53
9
246
20

4
Bayern Munich
 Germany
838
0
9
262
62

5
A.C. Milan
 Italy
824
0
-10
305
46

6
Juventus
 Italy
567
17
-18
321
45

7
Inter Milan
 Italy
555
n/a
10
264
26

8
Chelsea
 England
537
28
6
283
-37

9
Barcelona
 Spain
535
12
22
331
12

10
Schalke
 Germany
471
53
45
157
37

11
Liverpool
 England
454
18
28
225
37

12
Lyon
 France
343
n/a
65
163
10

13
Newcastle United
 England
260
46
-14
159
11

14
Tottenham Hotspur
 England
243
0
27
137
9

15
Roma
 Italy
224
0
-15
162
53

16
Hamburg
 Germany
221
n/a
n/a
130
31

17
Manchester City
 England
208
83
-6
114
9

18
Borussia Dortmund
 Germany
199
126
61
114
1

19
Ajax
 Netherlands
196
0
13
95
9

20
Celtic
 Scotland
185
14
18
106
-8

21
Everton
 England
165
32
34
107
-15

22
Marseille
 France
157
n/a
n/a
105
6

23
West Ham United
 England
156
27
n/a
111
6

24
Rangers
 Scotland
147
7
32
113
12

25
Aston Villa
 England
140
16
16
91
-21