forms of execution employed. The most popular is lethal injection followed by the electric chair and the gas chamber. Also, Utah makes use of shooting and Washington still employs hanging as a method of execution (Kronenwetter, 1993). Recently, the death penalty has come under fire from critics who question both its effectiveness and its legality. Traditionally, the death penalty has been challenged as a violation of the Eighth Amendment of the Constitution which provides for protection against "cruel and unusual" punishment. The Supreme Court has, however, ruled against this, upholding the legality of the death penalty in the case of Gregg v. Georgia. More recently, the Ninth United States Circuit Court of Appeals has ruled that execution by hanging is not a form of cruel and unusual punishment. Specifically, the majority opinion stated that they "could not conclude that judicial hanging is incompatible with the evolving standards of decency simply because few states continue the practice (Goldberg, 1994). If hanging is considered constitutional, then the three most common forms of execution, lethal injection, electrocution, and gas chamber, which are indeed more humane, are certainly not "incompatible with the evolving standards of decency." Therefore, they are not in violation of the Eighth Amendment, making them legal forms of punishment. If the death penalty has been declared legal, and thereby humane, then the federal and state governments must employ it to its fullest as a means of deterring previous murderers from recommitting their crimes. Since most of the prisoners on death row are there for murder, executing them would ensure that they would never kill again whether guards and inmates while still in prison, or innocent citizens if they were to escape. This applies particularly to criminals such as Westley Allen Dodd who was executed in Washington state in 1993 for the rape and murder of three young boys. He cl...