Which of the following is not an explanation for why Texas has one of the most controversial death penalty systems in the United States?

a. The court of criminal appeals has overturned no death penalty cases.
b. The court-appointed lawyers the state provides for defendants have often been subpar.
c. There are racial and ethnic disparities in who receives the death penalty and who does not.
d. Texas has led the nation in the number of executions since 1976.
e. Since 1977, the electric chair has been the means for execution in Texas.