Robert Lee Massie was executed by the state of California. Massie had voluntarily ended his appeals process after nearly thirty years on death row. Young Elk's request for a sacred sweat lodge, a purification ceremony equivalent to a Catholic's last rites, was denied. Williams is executed.
Lethal injection is now sole the method of execution.
Inmates may now choose between injection and lethal gas. 1972 California Supreme Court declares the death penalty cruel and unusual punishment in violation of the state constitution. 107 inmates are taken off death row and resentenced. A similar decision is rendered in 1976. Aaron Mitchell becomes the 194th person executed in the gas chamber and the last executed until 1992.