What is the test for a jury to return a verdict of death in a murder trial?

8. Only one verdict of death was returned and this was read in open court. It did not specify the count or counts for which the jury determined death was the appropriate penalty. We have held that this is not error or a defective verdict. (People v. Hines (1997) 15 Cal.4th 997, 1070-1071, 64 Cal.Rptr.2d 594, 938 P.2d 388; People v. Crittenden (1994) 9 Cal.4th 83, 159, 36 Cal.Rptr.2d 474, 885 P.2d 887.) However, in practice this rule could be troublesome in a case in which conviction on one of several murder counts is reversed as judgment is not pronounced on each count of which defendant is convicted. For this reason, the better practice is to provide the jury with verdict forms for each count on which the penalty must be imposed and to impose a penalty on each count.