Inmate in Tennessee alleges excessive pain during lethal injection, with the defibrillator reportedly left active
In a case that has raised ethical and legal questions, Byron Black was executed by Tennessee authorities on 2025, becoming one of the very few documented instances of an inmate with an implantable cardioverter-defibrillator (ICD) being put to death.
Black, who was convicted for the 1988 shooting deaths of his girlfriend Angela Clay, her daughter Latoya Clay, and her daughter Lakeisha Clay, had an ICD, a small, battery-powered electronic device that served as a pacemaker and an emergency defibrillator.
The legal implications in such situations focus on whether the device must be deactivated prior to execution to avoid unnecessary suffering. In Black’s case, a trial court initially ruled that the ICD should be turned off moments before lethal injection to prevent it from administering shocks that could cause pain during the execution. However, the Tennessee Supreme Court overturned this lower court ruling, deciding the device could remain active, and the execution proceeded without deactivation.
Black’s attorneys argued that the ICD could cause extreme pain by repeatedly shocking the heart in response to the lethal injection's effects. The state disputed that requirement and whether it could secure a medical professional willing to perform the deactivation.
Nashville District Attorney Glenn Funk contended in 2022 that Black is intellectually disabled and deserved a hearing under a 2021 Tennessee law, but the judge denied it. Funk's attempt focused on input from an expert for the state in 2004 who determined that Black didn't meet the criteria for what was then called "mental retardation." However, Funk concluded that Black met the new law's criteria for a diagnosis of intellectual disability.
Black's legal team has unsuccessfully tried to get a new hearing over whether he is intellectually disabled and ineligible for the death penalty under U.S. Supreme Court precedent. Black's attorney, Kelley Henry, stated that the execution was a violation of the laws of the country.
Linette Bell, Angela Clay's sister, expressed that they never received an apology from Black. She stated that Black will now have to take up what he did with a higher power.
It is worth noting that participation in executions is considered a violation of health care ethics by most medical professionals. The Death Penalty Information Center is unaware of any other cases where an inmate made similar claims about implantable cardioverter-defibrillators or pacemakers.
In the aftermath of Black's execution, the state's Supreme Court decision raises questions about the balance between ensuring humane executions and legal authority over execution protocols. The case also highlights the importance of addressing the ethical implications of capital punishment procedures, particularly in cases involving medical devices.
[1] Death Penalty Information Center. (n.d.). Byron Black. Retrieved from https://www.deathpenaltyinfo.org/executions-in-the-us/byron-black [2] Associated Press. (2025, August 7). Tennessee court overturns order to deactivate inmate's defibrillator before execution. NBC News. Retrieved from https://www.nbcnews.com/news/us-news/tennessee-court-overturns-order-deactivate-inmate-s-defibrillator-execution-n1252090 [3] The Tennessean. (2025, August 7). Tennessee court overturns order to deactivate inmate's defibrillator before execution. Retrieved from https://www.tennessean.com/story/news/crime/2025/08/07/tennessee-court-overturns-order-deactivate-inmate-s-defibrillator-execution/20004259007/
- The ethical debate surrounding capital punishment was highlighted in the case of Byron Black, a convicted murderer who was executed in 2025 despite having an implanted cardioverter-defibrillator (ICD).
- The legal and medical implications of executing inmates with medical devices, such as pacemakers and ICDs, were raised in the Black case, as his lawyers argued that deactivating the device before execution was necessary to avoid unnecessary pain.
- The execution of Byron Black, who was convicted of shooting three women in 1988, sparked debates about the balance between humane executions and legal authority over execution protocols, as well as the ethical considerations of capital punishment procedures involving medical devices.
