After just four years, thirty-seven states have passed new death penalty laws designed to overcome the Supreme Court's concerns about the arbitrary imposition of the death penalty. Statutes were created instructing bifurcated trials, with separate guilt-innocence and sentencing phases, as well as imposing standards to guide the discretion of juries and judges in imposing death sentences, were upheld in a series of Supreme Court decisions in 1976 in Gregg v. Georgia. According to Mandery (2012), “Georgia has reformed its death sentencing system in three significant ways: (1) it has bifurcated trials; (2) created a number of statutory aggravating circumstances, at least one of which must be found by the jury to be proven beyond a reasonable doubt; and (3) required the automatic appeal of all death sentences to the Georgia State Supreme Court to determine whether the sentence was disproportionate to sentences imposed in similar cases” (p.135). By creating these three new statutes, states wanted to ensure that arbitrariness was not part of the judicial procedure. “The pattern of aggravating circumstances is much more significant than that