Ronald George is a former Chief Justice of the California Supreme Court, who regularly upheld death sentences. However, in his recent book, Chief: The Quest for Justice in California, he questioned the geographical disparities in the application of the death penalty in the state. In his chapter, "Reforming the Judicial System," he wrote, "You could have the exact same crime, let's say a straightforward street robbery homicide, result in the seeking of the death penalty in one part of the state and not in the other, among various defendants with similar past histories and records. This, to me, raises some troubling issues. I'm not saying I find this necessarily rises to the level of a constitutional infirmity, but it may raise policy concerns about the manner in which the death penalty is administered in California." Similar disparities were highlighted in DPIC's recent report, "The 2% Death Penalty," which noted that, in 2009, only 3 counties in California were responsible for 83% of the death sentences, and almost all sentences (96.6%) came from just 6 of the state's 58 counties.