California, United States of America
The following excerpt is from People v. Townsel, 201 Cal.Rptr.3d 19, 368 P.3d 569, 63 Cal.4th 25 (Cal. 2016):
The failure to require that the jury make written findings during the penalty phase did not violate defendant's rights under the Sixth, Eighth, and
[63 Cal.4th 73]
Fourteenth Amendments. (People v. Mai (2013) 57 Cal.4th 986, 1057, 161 Cal.Rptr.3d 1, 305 P.3d 1175.)
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