In September 2007, a federal judge held that Tennessee's revised death penalty protocols [text, PDF; JURIST report], devised earlier that year by the Tennessee Department of Corrections at the request of then-governor Phil Bredesen, did not ensure that prisoners' are properly anesthetized before they receive a lethal injection and thus constitute "cruel and unusual" punishment. Bredesen ordered a moratorium on executions [executive order, PDF; JURIST report] earlier that year and directed the Tennessee Department of Corrections to review the manner in which death sentences are administered. Bredesen accepted new protocols and the state conducted its first execution [JURIST report] under the new rules in May 2007. The protocol included more detailed guidelines for administering lethal injections but still includes a controversial three-drug "cocktail" which some said may be ineffective in preventing inmates from suffering a painful death [JURIST report]. The number of executions that took place in the US in 2010 was down 12 percent from 2009, according to the Death Penalty Information Center (DPIC) [advocacy website] annual report [text, PDF; JURIST report]. DPIC attributes the decrease in executions to several factors, including controversy over lethal injections [JURIST news archive]. The report also states that a recent poll shows 61 percent of Americans would choose various alternative sentences over the death penalty as the proper punishment for murder. Executions resumed in the US in April 2008 after the Supreme Court lifted an effective ban on the death penalty by upholding the constitutionality of lethal injection [JURIST report].