Congress acted defiantly toward the Supreme Court by passing the Drug Kingpin Act of 1988 and the Federal Death Penalty Act of 1994 that made roughly fifty crimes punishable by death, including crimes that do not always involve the death of someone. Such non-death capital offenses include treason, espionage (spying for another country), and high-level drug trafficking. Since no one has yet been sentenced to death for such non-death capital offenses, the Supreme Court has not ruled on their constitutionality.