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Sentencing decisions within the United States are often inconsistent and affected by biases unrelated to evidence and facts surrounding murder cases. This publication reviews current state laws involving "Heinous, Atrocious, or Cruel" statutes and how their application affects appellate court decisions after sentencing in regards to murder cases. Additionally, specific factors are identified and analyzed, including mode of murder and the presence of a sexual offense in order to determine if specified factors do, in fact, affect determinations in these appellate court case decisions.