The case for abolishment is grounded in arguments that it constitutes cruel and unusual punishment proscribed by the 8th and 14th amendments. While these efforts were unsuccessful, the death penalty was increasingly challenged on constitutional grounds, leading to the 1968-1976 moratorium on executions. In Furman v. Georgia, the Court held that sentencing authorities could not exercise untrammeled discretion in capital cases, but must use rational standards in making their determinations. This resulted in a reversal of over 600 convictions of death cell inmates in States with mandatory capital sentencing laws. In Gregg v. Georgia, the Court held that the death penalty does not invariably violate the cruel and unusual punishment clause. Since the lifting of the moratorium, the death penalty has been challenged on other grounds, but the Court has rejected such challenges. Despite the Court's procapital punishment stance, opponents of the death penalty may still seek relief through Congress and State legislators, courts, and governors. These legislators and judges cannot escape the reality that the execution of death row inmates is no more than governmental mass murder. 36 footnotes.