The Oregon Supreme Court then ruled in October 2021 that carrying out the death penalty against individuals whose crimes were no longer statutorily eligible for the death penalty constituted disproportionate punishment prohibited by the state constitution. In August 2019, the Oregon state legislature passed a new law that narrowly limited the crimes for which the death penalty may be imposed. That same day, Governor Jared Polis commuted their death sentences. On March 23, 2020, Colorado prospectively abolished the death penalty, leaving three people on death row. However, the repeal was not retroactive, leaving one person on the state's death row. In May 2019, the New Hampshire legislature voted to abolish the death penalty. On October 11, 2018, the Washington Supreme Court declared the state's death penalty statute unconstitutional, saying that it was applied in an arbitrary and racially discriminatory manner. In December 2016, the court ruled that its decision applied to the 13 remaining prisoners on the state's death row. On August 2, 2016, the Delaware Supreme Court held that the state's capital sentencing procedures were unconstitutional and struck down Delaware's death penalty statute. On January 20, 2015, Governor Martin O’Malley commuted the sentences the four remaining death-row prisoners. The bill, signed into law in May 2013, left five men on the state's death row, one of whom subsequently died of natural causes. In March 2013, the Maryland legislature voted to prospectively abolish the death penalty. The Court reaffirmed that holding in May 2016 and reiterated that the state's remaining death row prisoners must be resentenced to life without possibility of parole. The Connecticut Supreme Court subsequently ruled in August 2015 that the death penalty violated the state constitution. By its terms, the repeal law did not affect the status of the 11 prisoners then on the state's death row. In April 2012, the Connecticut legislature voted to abolish the death penalty for future crimes. The New Mexico Supreme Court vacated those sentences on Jand ordered the two prisoners be resentenced to life in prison. However, the repeal was not retroactive, leaving two people on the state's death row. In March 2009, New Mexico voted to abolish the death penalty. The legislature has voted down attempts to restore the statute. In 2007, the court ruled that its prior holding applied to the last remaining person on the state's death row. In 2004, the New York Court of Appeals held that a portion of the state's death penalty law was unconstitutional. The legislature repealed the law and removed it from the state criminal code in 1984. In 1979, the Supreme Court of Rhode Island held that the state's statute imposing a mandatory death sentence for a prisoner who killed a fellow prisoner was unconstitutional.
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