The current practice of execution by lethal injection creates a substantial and foreseeable risk of causing extreme pain

Florida's lethal injection method of execution as practiced
creates an unacceptable foreseeable risk of unnecessary and extreme pain
and therefore violates the Eighth Amendment
to the U.S. Constitutional and Article I, Section 17 of the Florida Constitution,
which prohibit cruel and unusual punishments.

This is not a claim that execution by lethal injection is unconstitutional per se.
Rather, the claim is that the current practice of execution by lethal injection
creates a substantial and foreseeable risk of causing extreme pain
for a number of reasons.

These include the cosmetic use of a paralytic drug,
the refusal to employ expertise,
personnel and equipment currently available in medical science,
and the State's insistence on secrecy.