convict must show that other alternative methods of execution exist and clearly demonstrate they would cause less pain than the state-determined one. Other criminal sentences Morrissey v. Brewer, The Supreme Court extended Fourteenth Amendment due process protection to the parole revocation process, hold that the due process clause of the Fourteenth Amendment requires a "neutral and detached" hearing body such as a parole board to give an evidentiary hearing prior to revoking the parole of a defendant and spelled out the minimum due process requirements for the revocation hearing. Gagnon v. Scarpelli, The Supreme Court issued a substantive ruling regarding the rights of individuals in violation of a probation or parole sentence. It held that a previously sentenced probationer is entitled to a hearing when his probation is revoked. More specifically the Supreme Court held that a preliminary and final revocation of probation hearings are required by Due Process; the judicial body overseeing the revocation hearings shall determine if the probationer or parolee requires counsel; denying representation of counsel must be documented in the record of the Court. Wolff v. McDonnell, In administrative proceedings regarding discipline, prisoners retain some of their due process rights. When a prison disciplinary hearing might result in the loss of good-time credits, due process requires that the prison notify the prisoner in advance of the hearing, afford him an opportunity to call witnesses and present documentary evidence in his defense, and furnish him with a written statement of the evidence relied on and the reason for the disciplinary action. Bearden v. Georgia, A sentencing court cannot properly revoke a defendant's probation for failure to pay a fine and make restitution, absent evidence and findings that he was somehow responsible for the failure or that alternative forms of punishment were inadequate to meet the State's interest in punishment and deterrence. Apprendi v. New Jersey, Other than the fact of a prior conviction, any fact that increases the penalty for a crime beyond the prescribed statutory maximum must be submitted to a jury and proved beyond a reasonable doubt. Blakely v. Washington, Mandatory state sentencing guidelines are the statutory maximum for purposes of applying the Apprendi rule. Graham v. Florida, A sentence of life imprisonment without the possibility of parole may not be imposed on juvenile non-homicide offenders. Miller v. Alabama, A sentence of life imprisonment without the possibility of parole may not be a mandatory sentence