Stacey Ian Humphreys was convicted in 2006 of multiple counts including malice murder and armed robbery, resulting in a death sentence. After exhausting his direct appeals and collateral review, the State of Georgia obtained an execution warrant for December 17, 2025. Humphreys filed a § 1983 action alleging that executing him while other similarly situated inmates were protected by a COVID-19 agreement violated his rights under the Equal Protection and Due Process Clauses. The agreement, reached between Georgia and the Federal Defender Program, paused executions for inmates whose final appeals concluded during the state's COVID-19 judicial emergency (March 14, 2020, to June 30, 2021). Humphreys's final appeal concluded after that period ended, placing him outside the agreement's scope. The district court denied his motion for a preliminary injunction and dismissed his case. Humphreys then sought an emergency stay of execution pending appeal of the district court's order.
The Eleventh Circuit addressed Humphreys's claims in two parts. First, regarding Equal Protection, the court acknowledged that the state treated Humphreys and 'Covered Inmates' (those whose appeals ended during the emergency) differently. However, the court applied rational-basis review, not strict scrutiny, because the classification did not implicate a fundamental right or a suspect class. The court found the state's distinction rationally related to legitimate interests: ensuring adequate preparation for clemency proceedings for those most affected by pandemic restrictions and maintaining the state's ability to enforce criminal penalties in a timely manner. The court reasoned that limiting the agreement to the emergency period was a rational way to address the specific backlog and procedural risks of that time without indefinitely frustrating the state's interest in carrying out sentences. Second, regarding Due Process, the court held that Humphreys failed to allege constitutionally inadequate process. While death row inmates have a liberty interest in clemency proceedings, the Constitution requires only 'minimal procedural safeguards.' The court noted that Humphreys had received fourteen days' notice of his clemency hearing and had not demonstrated that the available process was fundamentally unfair.
The denial of the stay allows the State of Georgia to proceed with Humphreys's execution as scheduled. The decision clarifies that states may create temporary procedural protections for specific groups of inmates during emergencies without violating the Constitution, provided the classification is rationally related to a legitimate government interest. The ruling leaves open the question of whether the conditions of the agreement itself have been satisfied for Covered Inmates, which remains litigated in Georgia state courts, but confirms that inmates outside the agreement's scope have no constitutional right to those same protections.