The following excerpt is from Creech v. Arave, 947 F.2d 873 (9th Cir. 1991):
14 See also, Proffit v. Florida, 428 U.S. 242, 255, 96 S.Ct. 2960, 2968, 49 L.Ed.2d 913 (1976) (approving "especially heinous, atrocious or cruel" limited to "the conscienceless or pitiless crime which is unnecessarily torturous to the victim").
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