1. Whether given the unique pattern in Alabama's recent executions, in which Defendants have misrepresented critical facts and prohibited access to courts or counsel, Mr. Mills is likely to succeed on his claim that unnecessary, cruel, and prolonged restraint on the gurney, as well as refusals to provide information regarding ongoing litigation or steps in the execution process violates the Eighth Amendment.

2. Whether, based on this unique and acute context where there can be no enforcement of the relief sought without the presence of counsel, Mr. Mills is entitled to the presence of counsel and access to courts pursuant to the Sixth Amendment and the Due Process Clause.

Whether Alabama's execution process violates the Eighth Amendment