Bobby Wayne Woods (October 11, 1965 – December 3, 2009) was an American convicted murderer, kidnapper and rapist executed by the state of Texas for the murder and rape of 11-year-old Sarah Patterson in 1997.
 Woods also received a 40-year sentence for the abduction of Patterson's younger brother, whom he beat unconscious and left for dead but who survived.
 On May 28, 1998, Woods was sentenced to death for Patterson's murder and was executed on December 3, 2009 after a failed appeal based on Woods's low IQ.
Killer Legends is a 2014 American documentary written and directed by Joshua Zeman for Chiller.
 Zeman and Rachel Mills, a researcher, investigate the real-life origins of several urban legends.
Capitalism: A Love Story is a 2009 American documentary film directed, written by, and starring Michael Moore.
 The film centers on the late-2000s financial crisis and the recovery stimulus, while putting forward an indictment of the current economic order in the United States and unfettered capitalism in general.
 Topics covered include Wall Street's "casino mentality", for-profit prisons, Goldman Sachs' influence in Washington, D.C., the poverty-level wages of many workers, the large wave of home foreclosures, corporate-owned life insurance, and the consequences of "runaway greed".
 The film also features a religious component where Moore examines whether or not capitalism is a sin and whether Jesus would be a capitalist, in order to shine light on the ideological contradictions among evangelical conservatives who support free market ideals.
Outrage is a 2009 American documentary film written and directed by Kirby Dick.
 The film presents a narrative discussing the hypocrisy of people purported in the documentary to be closeted gay or bisexual politicians who promote anti-gay legislation.
 It premiered at the 2009 Tribeca Film Festival before being released theatrically on May 8, 2009.
 It was nominated for a 2010 Emmy Award, and won Miami Gay and Lesbian Film Festival's jury award for best documentary.
South of the Border is a 2009 American documentary film directed by Oliver Stone.
 The documentary premiered at the 2009 Venice Film Festival.
 Writer for the project Tariq Ali calls the documentary "a political road movie".
 Stone stated that he hopes the film will help people better understand a leader who is wrongly ridiculed "as a strongman, as a buffoon, as a clown."
Joshua Earl Patrick "Josh" Phillips (born March 17, 1984) is an American convicted murderer from Jacksonville, Florida.
 He was convicted in July 1999 of murdering an 8-year-old neighbor, Maddie Clifton, in November 1998, when he was 14 years old.
 He is currently serving a sentence of life in prison without parole.
 The murder was the subject of national television coverage, including a documentary on "48 Hours" titled "Why did Josh Kill?"
New Jersey: The Movie is a 2009 American documentary film written and directed by Steve Chernoski.
 The film examines the cultural divide that exists in the state of New Jersey between North and South.
Dirt!
 The Movie is a 2009 American documentary film directed by filmmakers Gene Rosow and Bill Benenson and narrated by Jamie Lee Curtis.
 It was inspired by the book "Dirt: The Ecstatic Skin of the Earth" by William Bryant Logan.
 The documentary starred environmentalists like Wangari Maathai, Vandana Shiva, Gary Vaynerchuk, Paul Stamets and Bill Logan.
 The film explores the relationship between humans and soil, including its necessity for human life and impacts by society.
 "Dirt!
 The Movie" was an official selection for the 2009 Sundance Film Festival and won several awards, including the best documentary award at the 2009 Visions/Voices Environmental Film Festival and the "Best film for our future" award at the 2009 Mendocino Film Festival.
Cropsey is a 2009 American documentary film written and directed by Joshua Zeman and Barbara Brancaccio.
 The film initially begins as an examination of "Cropsey", a boogeyman-like figure from New York City urban legend, before segueing into the story of Andre Rand, a convicted child kidnapper from Staten Island.
Andre Rand (born Frank Rushan; March 11, 1944) is an American convicted kidnapper of two children and suspected serial killer, currently serving 25 years to life in prison.
 He is eligible for parole in 2037.
 He is the subject of the 2009 documentary "Cropsey".

Question: In which year is the American convicted kidnapper eligible for parole, whose story is covered in the 2009 American documentary film written and directed by Joshua Zeman?
Answer: 2037