After only four short years, thirty-seven states have passed new death penalty laws intended to address the Supreme Court's concerns about the arbitrary imposition of the death penalty. Laws providing for split trials, with separate guilt phases and sentencing phases, as well as imposing standards to guide the discretion of juries and judges in imposing capital sentences, were upheld in a series of Supreme Court decisions in 1976 in Gregg v. Georgia. According to Mandery (2012), “Georgia reformed its death penalty system in three significant ways: (1) it split trials; (2) it created a set of statutory aggravating factors, at least one of which must be found by the jury to be proven beyond a reasonable doubt; and (3) it required the automatic appeal of all death sentences to the Supreme Court of the State of Georgia to determine whether the sentence was disproportionate to sentences imposed in similar cases” (p. 135). By creating these three new laws, the states wanted to ensure that arbitrariness would not be part of the legal process. “The pattern of aggravating circumstances is much more significant from the point of view