In some cases, evidence unerringly proves the participation of all accused persons when their number exceeds one in the commission of an offense. However, this evidence may fail to indicate the quality of individual participation for some or all of the accused. Judging the evidence to establish the accused persons’ participation beyond reasonable doubt for the purpose of conviction is distinct from assessing the degree or quality of individual involvement by a particular accused in the offense.

This distinction remains true even in cases where the nature of the crime is revolting, diabolical, notoriously depraved, and heinously gruesome.

In exceptional cases, the quality or degree of individual participation in the crime warrants separate consideration when determining the appropriate sentence for a particular accused. If there is no evidence or circumstantial indication justifying a death sentence for any particular accused individually, it is proper to impose a life sentence instead to avoid potential errors in sentencing.