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Third Time the Charm?

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A third jury has decided that serial killer Rodney Alcala should be sentenced to death for five murders, including that of a 12-year-old girl. Gillian Flaccus has this story for AP. The previous judgment was overturned by the Ninth Circuit. The story says the jury "recommended" death, but in California the jury returns a verdict, not a recommendation.

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How about an AEDPA tweak--if a guy is sentenced to death a second time, then no federal review of the sentence?

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