The most common method used in lethal injection executions in the United States has been upheld by the Supreme Court. A constitutional challenge was made regarding the State of Kentucky's use of the three drugs that sedate, paralyze and, finally, kill inmates. The argument against the three-drug protocol was that if the initial drug failed to sufficiently sedate the inmate, the administration of the other two drugs could result in excruciating pain which the inmate could not express due to paralysis.This method of execution is employed by approximately three dozen states. Executions have been on hold since September 2007 when the high court agreed to hear the Kentucky case.