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The Eighth Amendment's ban on cruel and unusual punishment has long prohibited the imposition of gratuitous pain. The most commonly used method of lethal injection violates that prohibition by using a sequence of drugs that creates an unnecessary risk of excruciating pain, and, for that reason, is prohibited by most veterinary guidelines. In its amicus brief, the ÀÏ°ÄÃÅ¿ª½±½á¹û points out that this unconstitutional practice has been facilitated by the secrecy surrounding the development and implementation of lethal injection protocols in most states.