 When serial killer Michael Bruce Ross agreed to be executed in 2005, his decision sparked controversy over whether he could legally agree to such a thing, as the death row phenomenon might have contributed to his decision.In Canada, the Supreme Court of Canada cited the death row phenomenon, along with a few other concerns about execution, to declare the risk of a prisoner being executed after he or she is extradited to another country to be a breach of fundamental justice, a legal right under Section 7 of the Canadian Charter of Rights and Freedoms in the Constitution of Canada.The case was "United States v. Burns" (2001).