By: Moises Ramirez Gomez
Journal of Global Rights and Organizations, Associate Articles Editor
WASHINGTON, D.C., United States – On September 18, 2026, the Inter-American Commission on Human Rights (“the Commission”) issued a report concluding that the United States is responsible for violating the rights of Tennessee death row prisoner Christa Pike, including her right to equality before the law under the American Declaration of the Rights and Duties of Man. Tennessee attempted to execute her by lethal injection, but the attempt failed. Afterward, the Tennessee Department of Correction stated that it followed every step of the state’s execution protocol, which does not allow for additional procedures.
Christa Pike appears in a Nashville court on April 12, 2012, in an earlier, separate case.
Pike was sentenced to death after the 1995 killing of Colleen Slemmer, which she committed at age 18. In the year 2020, attorneys from Cornell Law School and the Federal Defender Services of Eastern Tennessee petitioned the Commission and requested precautionary measures, arguing that her trial counsel failed to present mitigating evidence, that she had endured prolonged solitary confinement, and finally, that Tennessee’s execution methods violated her rights. Alongside this, they argued that, as the only woman on Tennessee’s death row, her isolation was a reflection of gender discrimination, because men on death row were housed together.
The Commission found violations of Pike’s rights to life, liberty and personal security, equality before the law, health and well-being, a fair trial, protection from arbitrary arrest, and due process. As a result, it recommended reparation, review and commutation of her sentence, her removal from solitary confinement, and reforms to ensure adequate counsel is given in capital cases. The Commission also noted that the American Declaration does not prohibit the death penalty in itself, but concluded that executing Pike after proceedings that violated her rights would be a serious violation of her rights to life and due process. The United States had objected earlier in the proceeding, telling the Commission in 2020 that Pike had not exhausted domestic remedies and that the jury considered her mental health as a mitigating factor.
Because the United States has signed but not ratified the American Convention on Human Rights, Pike’s case was assessed by the Commission under the Declaration rather than by the Inter-American Court. The Commission first sent its findings to the United States on October 15, 2025. Here, they asked for information on compliance within one month. According to Diplomacy and Law, a legal commentary site, the findings do not change Pike’s Tennessee sentence, nor do they act as a stay in Tennessee courts. Alongside this, the same commentary points that Report 197/26, the Commissions published decision on the Pike’s case, does not say whether Tennessee can attempt a second execution.
Considering this analysis, whether international law limits a second execution attempt is unresolved. Report 197/26 does not address a repeat attempt, and there is no applicable treaty provision or Inter-American decision it reviewed that bars one outright. On October 1, the UN human rights chief and nine UN experts urged Tennessee not to pursue another attempt. The governor has halted the remaining 2026 executions, and has additionally ordered an independent review. The state says the Tennessee Supreme will decide whether to set a new date.
In conclusion, Pike’s case leaves two questions open: what effect the Commission’s findings will have in Tennessee, and whether a second lethal injection attempt is permitted.
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