“Based on Dr. Heath’s medical findings and conclusions, and given Mr. Hamm’s cranial and lymphatic cancer, there is a substantial likelihood that the Alabama Department of Corrections will not be able to accomplish a successful execution in compliance with the Eighth Amendment,” counsel argued to the Alabama Supreme Court. In a lengthy 59-page brief and appendices, counsel detailed the multiple ways in which Doyle Hamm’s cranial and lymphatic cancer would interfere with a lethal injection and result in a botched execution. Counsel urged the Court not to set an execution date. The details are all here in the pleading:
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