had a legal obligation to abandon her views for the sake of unanimity, the trial court’s message served to heighten the frustrations of the jurors by indicating nothing more than the court was powerless to address the majority jurors’ apparently valid concerns. As indicated by defense counsel’s objection, and under all the circumstances, the coercive nature of the trial court’s handling of the jury’s note was readily apparent at that time. Id. The jury’s note also contributed to an atmosphere of coercion in other ways. Hooks asserts the jury’s note, which disclosed the panel’s numerical division and that an eleven-to-one majority favored death, further increased the pressure on the holdout juror to accede to the majority’s wishes and change her vote. Id. at 239-41, 108 S.Ct. 546 (<HOLDING>). In the exercise of its supervisory powers
recognizing that in certain circumstances inquiry notice may be determined as a matter of law recognizing that a previous panels review of the same habeas petition is the law of the case holding that the impact upon the victims is relevant to circumstances of the crime recognizing that in certain circumstances polling of the jury could be relevant to the question of coercion on habeas review holding that in certain circumstances fraud can be prosecuted under the statute