Glossip v. Gross (14-7955)

argument 14-7955

Glossip v. Gross

Supreme Court of the United States 1h 3m 7 speakers 8 chapters transcribed 4 days ago official recording ↗
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What is the central legal issue the Court is addressing in Glossip v. Gross?

John G. Roberts 0:01
We'll hear argument first this morning in case fourteen seventy nine fifty five. Glossop versus gross. Yes, Conrad?
Conrad (Unknown) 0:09
Mr Chief Justice, and may it please the Court, Oklahoma chooses to execute our clients with a three drug formula that includes a paralytic in potassium chloride. drugs that cause intense pain and suffering. The second and third drugs are constitutional. Only if a prisoner will not feel the pain and be aware of the suffocation caused by those drugs. The district court aired as a matter of law and as a matter of fact when it found that medazolam as the first drug is constitutionally tolerable.
Antonin Scalia 0:46
Why is that uh A matter of law. I mean as I see it it's just a just a fact question and and and and the district court found that uh It uh it did uh eliminate the pain. And you you're asking us to find that the district court uh was clearly erroneous in that determination. Do we usually do that kind of thing?
Conrad (Unknown) 1:09
Justice Clea, the there's a question of law and there's a question of facts.
Antonin Scalia 1:13
What's the question of law?
Conrad (Unknown) 1:15
The question of law includes the the fact that the district court found that this three drug formula was constitutionally tolerable in spite of two facts. The first one being that there is a medical consensus that this drug cannot be used as the sole drug.
Antonin Scalia 1:34
That's a question of fact. You're saying the the question of law is that the the district court ignored two facts. Ignoring two facts does not make it a question of law. It's still a question of fact.
Conrad (Unknown) 1:46
The if if I can, Justice Scalia, the second point is the question of law also involves that the district court found that this drug creates a greater risk of harm than sodium thiopentol but that it could not quantify. So it found that this drug that creates a greater risk of harm that it could not quantify, and it also had before it evidence that this drug is not used for the purpose that which the state intended to
Elena Kagan 2:17
be used. Um I the way I've thought of this, and I know that in your brief you think de novo review goes to everything, if I disagree with you. If I think that I have to give deference to the district court's factual finding on how this drug works. The mis um what how do you call it? The medi
Conrad (Unknown) 2:38
the medazolam.
Elena Kagan 2:39
Medazolan. Um But that it's a legal question. of whether how that drug works creates a risk of harm that's constitutionally intolerable. Is that how you divide up the legal and
Conrad (Unknown) 2:58
Yes, Justice Sotomayor. So
Elena Kagan 2:59
the facts are now let's go to my real question, okay? Um that a judge ignores evidence is not necessarily and abuse of discretion. or a clear error. But so what are the clear errors? In terms of the reasoning that the district court used.
Conrad (Unknown) 3:24
So the clear errors in this case w we have to look at what this case is about and this case is about known information and undisputed facts that were before the court. This drug, Medazolam, is in a different class than barbituates. This drug is not known it's not a pain reliever. The district court recognized these two facts at seventy six of the joint appendix. It's known that this drug has a ceiling effect. So there's a certain point at which giving more of the drug is not going to matter. The district court recognized that at seventy-eight. The state's expert recognized that. The petitioners experts recognize that.
John G. Roberts 4:02
Well, but what the the district court determined is that it was uh it was not able to tell precisely when the ceiling effect kicked in, precisely when they hit the ceiling, right? That is your theory for when uh uh pain is possible when it hits the ceiling, right?
Conrad (Unknown) 4:19
What the district court found, uh, Mr. Chief Justice, is whatever the ceiling effect may be, it takes effect only at the spinal cord. And that 500 milligrams of medazolam will, quote, create a phenomenon which is not anesthesia. But effectively paralyzes the brain and eliminates awareness of pain. Now that finding we have to we have to look at what undisputed facts were before the court in making that finding. But is it
John G. Roberts 4:45
undisputed facts? I thought you had the burden of showing that the determinations were clearly erroneous.

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