context: As such, some states employ the reasonable doubt standard in determining the appropriateness of the death penalty. Others, however, have rejected the argument that the failure to require the jury to find that death is appropriate beyond a reasonable doubt renders a death penalty statute unconstitutional.
citation_a.signal: see also
citation_a.identifier: 473 N.E.2d 264, 280
citation_a.parenthetical: jury need not be statutorily required to determine death penalty is appropriate where procedural safeguards ensure appropriateness
citation_a.sentence: See also State v. Jenkins, 15 Ohio St.3d 164, 473 N.E.2d 264, 280 (1984) (jury need not be statutorily required to determine death penalty is appropriate where procedural safeguards ensure appropriateness).
citation_b.signal: see
citation_b.identifier: 802 P.2d 330, 362
citation_b.parenthetical: again rejecting claim that U.S. Constitution requires instruction that jury must find death is appropriate beyond a reasonable doubt
citation_b.sentence: See, e.g., People v. Benson, 52 Cal.3d 754, 276 Cal.Rptr. 827, 802 P.2d 330, 362 (1990) (again rejecting claim that U.S. Constitution requires instruction that jury must find death is appropriate beyond a reasonable doubt).