In 2012, the National Academy of Sciences picked apart immense bodies of research and bluntly issued cease and desist warnings, claiming the studies have been flawed or futile. Former U.S. Court of Appeals Judge H. Lee Sarokin might have put it best when he wrote in 2011: "Persons contemplating murder do not sit around the kitchen table and say I won't commit this murder if I face the death penalty, but I will do it if the penalty is life without parole."