States since 1967. In the post-Gregg era, Texas has executed 581 people. There are a variety of proposed legal and cultural explanations as to why Texas has more executions than any other state. One possible reason is due to the federal appellate structure—federal appeals from Texas are made to the United States Court of Appeals for the Fifth Circuit. Michael Sharlot, dean of the University of Texas at Austin Law School, found the Fifth Circuit to be a “much more conservative circuit” than the Ninth Circuit, to which federal appeals from California are made. According to him, the Fifth is “more deferential to the popular will” that is strongly pro-death penalty, and creates few legal obstacles to execution within its jurisdiction. As of 2004, however, Texas may have a lower rate of death sentencing than other states, according to a study by Cornell University. Texas has executed nine women in its history, the most recent being Lisa Ann Coleman on September 17, 2014. In 2005, the state of Texas passed a law allowing life imprisonment without parole as an option for capital cases. Maurice Chammah, author of Let the Lord Sort Them: The Rise and Fall of the Death Penalty, stated that governments of smaller counties supported the move, as death penalty cases had increasing costs due to lengthy appeals processes. By 2021, the usage of the death penalty in Texas courts was on the decline. Rose Calahan of Texas Monthly stated that by that year, the death penalty became less of a wedge issue in politics. There were three executions in 2020, the smallest number of executions per year since 1996, which also had 3. In 2020, two persons were sentenced to death, making it the post-1974 year with the lowest number of people sentenced to death. Capital crimes Under Texas statutes, a murder is capital if the offender: Murders a peace officer or fireman who is acting in the lawful discharge of an official duty, and who the person knows is a peace officer or fireman. (There have been bills proposed to add EMT/paramedics to this list.) Intentionally commits the murder in the course of committing or attempting to commit aggravated kidnapping, burglary, robbery, aggravated sexual assault, arson, obstruction or retaliation, or terroristic threat. Commits the murder for remuneration or the promise of remuneration, or employs another to commit the murder for remuneration or the promise of remuneration.