It is also the one with the most protections against it. An inmate cannot be executed for crimes that do not cause someone's death. This has not always been the case, but in Gregg v Georgia (1976) the Supreme Court established a rule that the death penalty can be used for crimes only if it is used for an acceptable purpose of punishment and cannot be grossly disproportionate to to the crime. This can be seen again in Coker v Georgia (1977), where the prisoner was sentenced to death after raping a woman. Although inmate Coker raped this woman after committing several crimes, none of them resulted in anyone's death. The court used Gregg v Georgia (1976) to establish that the death sentence was not proportional to the crime of rape. The death penalty has an “evolving standard of decency” that changes as society changes (Trop v Dulles, 1957). The Supreme Court addressed this issue in Ford v. Wainwright (1986). Ford was convicted of murder but several years later developed mental problems where he could not understand why he was being executed. The court held that the Eighth Amendment; “prohibits the State from inflicting the death penalty on an insane prisoner.” This was reiterated in Atkins v Virginia (2002) and Roper v Simmons (2004). These cases summarize the court's decision that if a prisoner cannot understand why he is executed