Proponents of the death penalty have shifted gears. In the past, gruesome public executions were extolled as a deterrent to others, and even in modern times death has been inflicted on convicted criminals by hanging, firing squads, electrocution and poisonous gas. All of these methods cause significant pain to the victim, and all have the potential for failure and added suffering — both physical and mental. Many have argued that all of these methods of execution are potentially or actually “cruel and unusual” means of punishment, and recent United States Supreme Court decisions have suggested that they could be declared unconstitutional on this basis.