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Lowenfield v. Phelps, 484 U.S. 231 (1988) is a United States Supreme Court case in which the Court held that the two jury polls and the supplemental charge did not impermissibly coerce the jury to return a death sentence, and that the death sentence does not violate the Eighth Amendment simply because the single statutory "aggravating circumstance" found by the jury duplicates an element of the underlying offense of first-degree murder.
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