On September 15, 2017, Doyle Hamm again updated the Alabama Supreme Court on his worsening medical condition and the danger that a lethal injection would cause unconscionable pain. Specifically, counsel explained to the Court that there may be a serious problem of access to his veins. The medical records contain, for instance, the following kind of medical indications: “S[ubject]: ‘Got blood vessels bursting in R[ight] foot and ankle. Been like this for a while but now it’s getting worse.’ D[octor]: Small broken vessels noted on top and side of R[ight] foot. Also ankle area.” See Wm. Donaldson Correctional Facility Patient Notes – 10.10.1991. This prior medical condition, in conjunction with his current cancer, may present significant barriers to humane venous access. For instance, the medical records reveal that Doyle’s “epidermis is ulcerated. Budding from the dermal epidermal junction are geometrically shaped tumor islands consisting of basaloid cells. The tumor islands are mitotically active and demonstrate peripheral palisading. There is peritumoral reactive fibroplasia and cellularity.” See Wm. Donaldson Prison Medical Records – 2.28.14. In combination with the indications of “lymphadenopathy,” see Wm. Donaldson Correctional Facility Medical Records – 3.7.17, these medical conditions suggest that it may be exceedingly difficult, if not impossible, for prison personnel to establish reliable intravenous access during the lethal injection procedure. This raises the unacceptable risk that Doyle would  experience significant pain constituting cruel and unusual punishment in violation of the Eighth Amendment. Whether the state of Alabama would proceed to central venous cannulation, or a “central line,” as the state of Georgia has done, is a critical question-and could be extraordinarily painful and dangerous given Doyle’s ongoing lymphadenopathy. For full details, see PLEADINGS folder.