Whether the Eighth and Fourteenth Amendments prohibit the execution of a death row inmate when substantial legal issues remain unresolved

warrant close consideration—which cannot be conducted in just a day or two. In addition, the irreversible nature of the death penalty favors granting a stay. “[A] death sentence cannot begin to be carried out by the State while substantial legal issues remain outstanding.” Barefoot, 463 U.S. at 888. Should the Court grant the request for a stay and review of the underlying petition, there is a significant possibility of the lower court’s reversal. This Court’s intervention is urgently needed to prevent Mr. Bates’ imminent execution in contravention of the Eighth and Fourteenth Amendments. CONCLUSION For the foregoing reasons, Mr. Bates respectfully requests that the Court grant his application for a stay of his August 19, 2025, execution to address the compelling constitutional questions in his case on the merits.