In its first death penalty case this term, the U.S. Supreme Court heard arguments in Brown v. Sanders, a California case in which the Justices considered whether Ronald Sanders was wrongly sentenced to die by jurors who relied on invalid aggravating factors. Sanders was sentenced to death in 1982. The jury found four of the “special circumstances” required in California and some other states for a defendant to be eligible for the death penalty. Two of those aggravating factors were later deemed invalid by the California Supreme Court and, in a later appeal, the U.S. Court of Appeals for the 9th Circuit threw out Sanders’ death sentence because jurors may have been unfairly swayed by the invalid special circumstances. The Justices must now determine whether the absence of the two invalid aggravating factors would likely have changed Sanders’ original sentence. Justice Stephen Breyer suggested that the Supreme Court might also want to clear up the differences that exist from one state to another in how aggravating factors are used in death penalty sentencing. “We would not have this crossword puzzle that only five people in the United States understand,” he said. (Associated Press, October 11, 2005). The U.S. Supreme Court has agreed to hear five death penalty-related cases this term. See U.S. Supreme Court.