Nance v. Oliver

CourtDistrict Court, N.D. Georgia
DecidedFebruary 13, 2025
Docket1:20-cv-00107
StatusUnknown

This text of Nance v. Oliver (Nance v. Oliver) is published on Counsel Stack Legal Research, covering District Court, N.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Nance v. Oliver, (N.D. Ga. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

MICHAEL WADE NANCE,

Plaintiff, v. CIVIL ACTION NO. 1:20-CV-00107-JPB TYRONE OLIVER, Commissioner, Georgia Department of Corrections,

Defendant.

ORDER This matter is before the Court following a bench trial on Michael Wade Nance’s (“Plaintiff”) claim that execution by lethal injection violates his rights under the Eighth and Fourteenth Amendments to the United States Constitution. Specifically, Plaintiff alleges that the lethal injection protocol in Georgia presents a substantial risk of severe pain to him because of his medical conditions. This Court finds as follows: RELEVANT PROCEDURAL HISTORY Plaintiff—an inmate convicted of malice murder and sentenced to death— filed this action against Defendants1 on January 8, 2020. [Doc. 1]. Plaintiff filed an Amended Complaint on April 7, 2023. [Doc. 58]. In the Amended Complaint,

Plaintiff contends that an execution by lethal injection will violate his constitutional rights because his veins are compromised in such a way that it is likely that he will suffer “excruciating pain” during the execution. Id. at 2.

Plaintiff further asserts that pentobarbital—the lethal drug used to render Plaintiff unconscious and stop his heart—could be ineffective or less effective because of his continuous exposure to gabapentin—a different drug that Plaintiff uses to treat his chronic back pain. Id. The Court thus construes Plaintiff’s Amended

Complaint to contain two causes of action: (1) a compromised vein claim; and (2) a gabapentin usage claim. Ultimately, Plaintiff argues that because of these unique medical conditions, he faces a substantial risk of severe pain if the current

execution protocols are utilized. Id. As an alternative to lethal injection, Plaintiff suggests death by firing squad. Id.

1 Defendants are Tyrone Oliver, the commissioner of the Georgia Department of Corrections, and Antoine Caldwell, the warden of the prison where Plaintiff is incarcerated. The Court held a five-day bench trial from May 20, 2024, through May 24, 2024. After the trial, both parties filed post-trial briefs. [Docs. 151, 152 and 153]. The Court now sets forth its findings of fact and conclusions of law in accordance with Federal Rule of Civil Procedure 52(a).

FINDINGS OF FACT Numerous witnesses testified at the bench trial, including Defendants, experts for both parties, members of the execution team assigned to carry-out

Plaintiff’s execution and witnesses of previous executions. The facts of this case are divided into the following sections: (A) the execution protocol in Georgia; (B) the execution team’s experience; (C) Plaintiff’s veins and the effect, if any, on the execution; and (D) Plaintiff’s gabapentin use and the effect, if any, on the

execution. A. The Execution Protocol in Georgia Under Georgia’s current execution protocol, the State injects the death row

inmate with five grams of pentobarbital. To inject the inmate with the drug, execution team nurses first obtain peripheral intravenous (“IV”) access in two places, usually in each of the inmate’s arms.2 [Doc. 150, p. 73]. These nurses are

2 If the nurses are unable to obtain peripheral IV access, a “physician will provide access by central venous cannulation” or through another “medically approved alternative.” fully qualified to place peripheral IVs and have extensive experience in obtaining peripheral IV access. Id. at 73, 137–38. After the IVs are placed, both IVs are checked for proper flow and a decision is made about which IV will be used for the primary infusion. Id. at 74.

In proceeding with the execution, [t]he first member of the Injection Team will inject one (1) syringe containing 2.5 grams of Pentobarbital (labeled #1). The second member of the Injection Team will inject an additional syringe containing 2.5 grams of Pentobarbital (labeled #2). The third member of the Injection Team will inject one (1) syringe containing 60 cubic centimeters of Saline (labeled #3), ensuring a steady, even flow of the chemical. Joint Exhibit 1, p. 7. The syringes containing the pentobarbital are injected over a one-minute period. The final syringe, which contains saline, is used to ensure that the entirety of the pentobarbital is delivered and pushed into the inmate’s cardiovascular system. [Doc. 147, p. 204]. During the execution, an IV nurse stands next to the inmate and monitors the injection site and the flow in the IV lines. [Doc. 150, p. 48]. This monitoring is

Joint Exhibit 1, p. 6. Central venous cannulation, or placing a central line, is described by the National Institutes of Health as a “standard” procedure. done so that any problems with the IV, such as extravasation,3 can be detected. If the nurse notices a problem with the IV, he or she notifies the physician who consults with the warden about how to proceed. Joint Exhibit 1, p. 7. B. The Execution Team’s Experience

Several members of the execution team testified during the trial, including one anonymous doctor and one anonymous nurse. Doctor Doe, who is a member of the execution team, is a board-certified

surgeon with over twenty years of experience. [Doc. 150, pp. 10–11]. Notably, Dr. Doe has participated in sixteen executions in Georgia, and in each of those executions, he oversaw the placement of the peripheral IVs in the inmates. Id. at 17. Under oath, Dr. Doe explained that he and the other injection team members

arrive hours before the scheduled execution and check all the supplies that they may need. Id. at 68–67. Once the execution begins and after the IVs are placed, Dr. Doe stated that he and the nurses check and test to ensure that the IV tubing for

the two peripheral lines are flowing properly. Id. at 71–72. Importantly, Dr. Doe was confident that the medical staff would be able to identify and correct any

3 Extravasation, or a blown vein, occurs when the liquid in the IV line leaves the patient’s vein and enters the soft tissue surrounding the vein. [Doc. 147, p. 99]. Extravasation can be painful because of the “physical displacement of the skin.” Id. Extravasation can also cause a burning sensation. Id. If extravasation occurs, it could render the pentobarbital ineffective or less effective. Id. issues with the IV tubing. Id. According to Dr. Doe, at all times during an execution, the medical team looks for signs of extravasation or other indications that the inmate is in significant pain. Id. at 75, 81. Dr. Doe testified that the medical team has a plan in place to deal with

complications, such as extravasation and/or the inability to obtain peripheral IV access. Id. at 77. Indeed, during one execution, Dr. Doe placed a central line. Id. at 17. This central line placement, which took approximately one hour, was just

one of an estimated 7,000 central lines that Dr. Doe has placed over the course of his career. Id. at 41–44. While Dr. Doe has never failed to obtain access via a central line, Dr. Doe admitted that some of these patients experienced complications, such as a nick to the femoral artery or a collapsed lung.4 Id. at 66–

67, 86. Dr. Doe maintained, however, that the complications were not serious in the vast majority of the cases. Id. Dr. Doe asserted that when he inserted the central line during the previous execution, the inmate never communicated to

medical staff that he was in significant pain. Id. at 79. Dr. Doe testified confidently that with six possible sites to insert a central line, if that were even

4 Dr. Doe stated that if he needs to place a central line for Plaintiff’s execution, he will use the right femoral vein because “the possibility of a pneumothorax [or collapsed lung] is zero.” [Doc. 150, p. 66].

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