In 1995, a Colorado jury convicted Robert Harlan of kidnapping, rape, and murder. Now his death sentence has been overturned because jurors illegally used Bibles while deliberating, and quoted "an eye for an eye." Juries, Colorado Judge John Vigil said, can use their personal convictions in deliberations, but not texts not introduced at trial. Harlan isn't alone: in 2000 the Supreme Court of Georgia and the 9th U.S. Circuit Court of Appeals overturned death penalties because prosecutors quoted Scripture. But that same year, Ohio's Supreme Court said such references didn't matter. In 1999 the U.S. Supreme Court turned away a Nebraska case in which a judge quoted Scripture in sentencing.

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