NO COURT OF LAST RESORT

JOE PAYNE, POSSIBLY INNOCENT, MAY BE EXECUTED IN THE WAKE OF PRESSURE TO LIMIT DEATH-ROW APPEALS

No one disputes the way in which David Wayne Dunford died. Shortly after cells in the C1 block of Virginia's Powhatan Correctional Center clanged open for Sunday breakfast on March 3, 1985, someone padlocked Dunford's cell, splashed flammable liquid through the bars and tossed in a lighted match. Dunford, a burglar, died in agony nine days later without naming his murderer.

But the Commonwealth of Virginia did. It decided on Joseph Patrick Payne, a soft-spoken, 40-year-old eighth-grade dropout who is scheduled to die by lethal injection on Nov. 7. Yet Payne, while hardly a model citizen, may be innocent of this...

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