In this habeas action not governed by the Antiterrorism and Effective Death Penalty Act of 1996, the Ninth Circuit found Sandoval was entitled to relief from the death sentence imposed for one of four murders of which he was convicted. Agreeing with Justice Mosk’s partial dissent in People v. Sandoval (1992) 4 Cal.4th 155, the Ninth Circuit held that Sandoval was denied a fair penalty phase trial when the prosecutor, in summation, relied heavily on religious authority in arguing to the jury that the death penalty was sanctioned by God. The use of the passage was both improper and highly prejudicial.