During both terms in office, Brown commuted 23 death sentences, signing the first commutation on his second day in office. One of his more notable commutations was the death sentence of Erwin "Machine-Gun" Walker, whose execution in the gas chamber for first-degree murder had been postponed because of an attempted suicide some hours before it was scheduled to take place. After Walker recovered, his execution was postponed while he was being restored to mental competency. After Walker was declared sane in 1961, Brown commuted Walker's death sentence to life without the possibility of parole. Walker was later paroled after the California Supreme Court held that Governor Brown could not legally deny a prisoner the right to parole in a death-sentence commutation. Another prisoner whose death sentence was commuted by Brown committed at least one murder after being paroled.