The following excerpt is from Michaels v. Chappell, CASE NO. 04cv0122-JAH (JLB) (S.D. Cal. 2014):
Thus, once the guilt phase jury unanimously found at least one of the charged special circumstances to be true beyond a reasonable doubt, the death penalty was within the statutory range of punishments. See Tuilaepa v. California, 512 U.S. 967, 975 (1994) ("A defendant in California is eligible for the death penalty when the jury finds him guilty of first-degree murder and finds one of the 190.2 special circumstances true."), citing Ramos, 463 U.S. at 1008. At the penalty phase, the jury
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