The legal administration of the death penalty in the United States is complex. Typically, it involves four critical steps: (1) sentencing, (2) direct review, (3) state collateral review, and (4) federal habeas corpus. Recently, a narrow and final fifth level of process – (5) the Section 1983 challenge – has become increasingly important. (Clemency or pardon, through which the Governor or President of the jurisdiction can unilaterally reduce or abrogate a death sentence, is an executive rather than judicial process.) The number of new death sentences handed down peaked in 1995–1996 (309). There were 73 new death sentences handed down in 2014, the lowest number since 1973 (44).