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Home / News Story / 4th Circuit: State’s argument does not trigger Simmons instruction (access required)

4th Circuit: State’s argument does not trigger Simmons instruction (access required)

A serial killer on North Carolina’s death row had no constitutional right under Simmons v. South Carolina to inform the sentencing jury that because he was already ineligible for parole, he did not pose a continuing danger to society, the 4th U.S. Circuit Court of Appeals has ruled. Lesley Warren had already been convicted of murdering ...

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