o. Absence of Requirement for Proportionality Review in Arizona's Scheme.

• Jurisdiction: Arizona

i. In Pulley v. Harris, the Supreme Court ruled that death sentences need not be subjected to a proportionality review. 104 S. Ct. at 875-76.

ii. In Walton, the Supreme Court held that Arizona’s scheme is not unconstitutional as not requiring a proportionality review. 110 S. Ct. at 3058.

iii. Citing Pulley, the Court has rejected the claim the proportionality review is constitutionally required. Salazar, 173 Ariz. at 416; Gulbrandson, 184 Ariz. at 73; McKinney, 185 Ariz. at 578.

iv. The scheme is

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