Executions resumed on January 17, 1977, when Gary Gilmore went before a firing squad in Utah. But the pace was quite slow due to the use of litigation tactics which involved filing repeated writs of habeas corpus, which succeeded for many in delaying their actual execution for many years. Although hundreds of individuals were sentenced to death in the United States during the 1970s and early 1980s, only ten people besides Gilmore (who had waived all of his appeal rights) were actually executed prior to 1984.