The Death Penalty in the OSCE Area 2006, the New Jersey state legislature passed a one-year moratorium on executions by the state, making New Jersey the first state to pass a moratorium pertaining to the death penalty through legislation, rather than by executive order. In December 2006, the one-year moratorium ended, and in January a report by the New Jersey Death Penalty Study Commission recommended abolishing the death penalty. New Jersey has not executed anyone since restoring the death penalty in 1982. Moratorium bills are under consideration in North Carolina, Oregon, Pennsylvania, and Texas. The Washington state legislature will consider a moratorium on executions in 2008. Capital punishment by lethal injection has been suspended in several states amid concerns about both the constitutionality of currently used lethalinjection protocols and whether the process is operating properly. In June 2004, New York’s highest court, the Court of Appeals, held that the central provision of the state’s law on capital punishment violated the state Constitution,107 and the state’s death penalty was overturned. Sustaining the court-ordered moratorium, in June 2006, members of the New York Assembly’s Codes Committee voted against a bill to reinstate the death penalty. Method of execution Although methods of execution vary from state to state, they include lethal injection, electrocution, the gas chamber, hanging, and shooting. The most common method of execution is lethal injection, which is either the sole method or a possible method of execution in all states except Nebraska, where the sole method of execution is electrocution. In 2006, 52 inmates were executed using lethal injection, and one inmate was executed by electrocution. All 26 executions that have taken place in the United States since January 2007 were carried out using lethal injection. On 12 June 2006, the United States Supreme Court ruled in Hill v. McDonough that convicted individuals could bring civil rights challenges against lethal injection as a method of execution. Although the Court did not rule on the constitutionality of lethal injection as an execution procedure, it determined that convicted individuals who believed that the protocol most commonly used for lethal injections caused unnecessary pain and suffering could pursue a claim under a civil rights statute. In December 2006, the governor of Florida suspended executions following a botched execution in which improper administration of the drugs in the lethalinjection protocol resulted in an execution that lasted about twice the usual time. In 107  The court found that the sentencing provisions were coercive because they required judges to tell juries in capital cases that, if they deadlocked and failed to reach a verdict during the sentencing phase of a trial, the judge would impose a more lenient sentence. 33