The patient was instructed to move the arm as far as possible in the requested direction with minimal additional movement (change of wrist/elbow position, undue rotation, change in body posture and similar efforts).
But will the Supreme Court agree with the lower courts, or has the definition of an undue burden changed yet again?
Mr. Moore's appeal was based on a change in execution protocol the state made in 2004, when a judge's decision that the use of four jolts of electricity appeared to cause undue suffering changed the practice to one continuous jolt for 15 seconds in an execution.
Environmental groups and editorial writers have demanded major changes, alleging undue influence from those who seek to build new coastal development projects.
However, the sheer volume of near-simultaneous changes created undue stress and affected morale.
Last year Radio 4 was criticised by the BBC Trust for giving undue prominence to the climate change sceptic Lord Lawson, founder of the Global Warming Policy Foundation, who appeared on the Today programme to claim that 2013 was "unusually quiet" for tropical storms.
But in reducing spending, government needs to ensure any changes will not cause undue harm to millions.
Nia Griffith, Labour's shadow defence secretary said there was a need to ensure the changes did not "cause undue challenges for our forces and their families" and asked what the government would do to minimise disruption.
In the end, rating agencies need to provide an honest and forward-looking assessment, and not be bound by the present system of relative ratings and undue concerns on reactions to their changes.
One claim, that James used undue influence over his father to change his will, was dismissed.
"As one school leader in Birmingham said to me, 'parents of the children in my academy are good people but were sometimes got at by outsiders to put undue pressure on the school to change its policies'".
