How have the courts treated the issue of quantifying the seriousness of a defendant's crime?

Thereafter, the prosecutor discussed with the jury the problem of "quantifying" the seriousness of defendant's crime. It is clear that the prosecutor was again discussing the crime from a qualitative or moral standpoint (People v. Haskett (1982) 30 Cal.3d 841, 863-864, 180 Cal.Rptr. 640, 640 P.2d 776): "How do we quantify, how do we measure the human suffering, the severity, the seriousness of these crimes we are now talking about? Ten different criminal transactions. We are talking about the three murders in this case, the executions, I shouldn't call them murders, executions in this case, conspiracy to commit the executions. How do we quantify that? How do we measure that when we are trying to weigh these aggravating circumstances ? [p] One way to do it, ladies and gentlemen, is to just, considering both these crimes and the executions in our case and the prior crime, is ... to look at it through the perspective of some of the victims." ³⁷ Turning to the mitigating circumstances, the prosecutor (as noted above) recognized the propriety of such evidence and argued forcefully that defendant's mitigating evidence was unpersuasive.