Throughout history, minorities have been ill-represented in the criminal justice system, particularly in cases where the possible outcome is death. In early America, blacks were lynched for the slightest violation of informal laws and many of these killings occured without any type of due process. As the judicial system has matured, minorities have found better representation but it is not completely unbiased. In the past twenty years strict controls have been implemented but the system still has symptoms of racial bias. This racial bias was first recognized by the Supreme Court in Fruman v. Georgia, 408 U.S. 238 (1972). The Supreme Court Justices decide that the death penalty was being handed out unfairly and according to Gest (1996) the S
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