In an article for the University of Richmond Law Review, Stephen Bright (pictured), President and Senior Counsel at the Southern Center for Human Rights, describes the arbitrary factors that continue to influence the death penalty. Bright first describes the historical context that led the Supreme Court to strike down the death penalty in 1976. He draws comparisons between lynchings, which he says were "used to maintain racial control after the Civil War," and capital punishment, which in 1976 "was very much tied to race - the oppression of African Americans, carried out by this country's criminal courts." He then explains how this legacy of racial bias continues today, saying, "The race of the defendant and the race of the victim continue to influence the imposition of the death penalty. The courts remain the part of American society least affected by the civil rights movement of the mid-twentieth century." Bright also addresses bias against the poor, and those with mental illness and intellectual disabilities. He concludes, "What purpose is the primitive penalty of death serving in a modern society? When we look closely at the issues - race, poverty, arbitrariness, conviction of the innocent, mental illness, and intellectual disability - from both a moral and practical standpoint, it will not be long before we join South Africa and the rest of the civilized world in making permanent, absolute, and unequivocal the injunction: 'Thou shall not kill.'"