psychiatrist James Grigson (who became known as "Dr. Death") was also a witness for the prosecution. Having conducted a psychiatric evaluation of Adams, he told the jury that Adams would be an ongoing menace if kept alive. As a result of this testimony, Adams was given the death penalty. His conviction was unanimously upheld by the Texas Courts of Appeals in 1979. In 1995, Grigson was expelled from the American Psychiatric Association and the Texas Society of Psychiatric Physicians for unethical conduct relating to expert witness testimony. Commutation of death sentence Adams's execution was originally scheduled for May 8, 1979, but U.S. Supreme Court Justice Lewis F. Powell, Jr. ordered a stay three days before the scheduled date. In 1980, the Supreme Court on an 8–1 vote ruled unconstitutional a Texas requirement for jurors to swear an oath that the mandatory imposition of a death sentence would not interfere with their consideration of factual matters, such as guilt or innocence, during a trial. As a result of the decision, Adams's death sentence was reversed and the Texas Court of Criminal Appeals granted him a new trial. Before the trial could begin, however, Texas Governor Bill Clements commuted Adams's sentence to life in prison at the request of the Dallas County District Attorney. Exoneration In May 1988, David Ray Harris, by that point himself a prisoner on death row, admitted that Adams was not even in the car on the night of the murder. The August 1988 release of the documentary film The Thin Blue Line, which detailed the many inconsistencies in the prosecution's line of reasoning, further cast doubt on Adams's guilt, but the case remained in legal limbo. In 1989, the Texas Court of Criminal Appeals in Ex parte Adams overturned Adams's conviction on the grounds of malfeasance by the prosecutor Douglas D. Mulder and inconsistencies in the testimony of a key witness, Emily Miller. The appeals court found that prosecutor Mulder withheld a statement by Emily Miller to the police that cast doubt on her credibility and also allowed her to give perjured testimony. Furthermore, the court found that after Adams' attorney discovered the statement late in Adams' trial, Mulder falsely told the court that he did not know the witness's whereabouts. The Texas Court of Criminal Appeals stated that "conviction was unfair mainly because of prosecutor Doug Mulder." Mulder had returned to practicing private law in Dallas