University of Minnesota Law School Scholarship Repository Minnesota Law Review 2014 Death Delayed Is Retribution Denied Russell L. Christopher Follow this and additional works at: https://scholarship.law.umn.edu/mlr Part of the Law Commons Recommended Citation Christopher, Russell L., "Death Delayed Is Retribution Denied" (2014). Minnesota Law Review. 241. https://scholarship.law.umn.edu/mlr/241 This Article is brought to you for free and open access by the University of Minnesota Law School. It has been accepted for inclusion in Minnesota Law Review collection by an authorized administrator of the Scholarship Repository. For more information, please contact
[email protected]. CHRISTOPHER_5fmt 11/30/2014 2:28 PM Article Death Delayed Is Retribution Denied Russell L. Christopher† INTRODUCTION In many of the top death penalty states, the leading cause of death for prisoners on death row is not lethal injection. Nor is it the electric chair. It is not even any form of execution. It is death by natural and other causes.1 From 1973–2011, in four of the top five states with the largest death row populations in 2011, more death row prisoners died of old age than were exe- cuted.2 In California during that period, for every one prisoner executed, six died on death row of other causes.3 In Pennsylva- nia during the same period, a death row prisoner was nine times more likely to die from other causes than by execution.4 The ballooning number of prisoners spending decades on death row who will die prior to execution stems from the combined ef- † Professor of Law, The University of Tulsa.