(ADDENDUM: It is sometimes suggested that the Court last examined the constitutionality of a method of execution in 1890, in the case of In re Kemmler, 11 years later than Wilkinson v. Utah. In the 1890 case, the Court found no constitutional violation in New York’s planned use of the electric chair to execute William Kemmler, a fruit peddler.in Buffalo. He was the first individual electrocuted in the U.S. The Court’s opinion did not deal with the issue under the Eighth Amendment, as in Wilkinson