California, United States of America
The following excerpt is from People v. Baker, 10 Cal.5th 1044, 274 Cal.Rptr.3d 655, 480 P.3d 49 (Cal. 2021):
In any event, the trial court merely used the word heinous ... as part of its explanation why it found the circumstances of the offense an aggravating factor." ( People v. Lucero (2000) 23 Cal.4th 692, 737, 97 Cal.Rptr.2d 871, 3 P.3d 248 ( Lucero ).)11
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