This misconduct is the one and only record-based explanation for the misunderstanding reflected in the jury’s note. In light of the record in this case, it would certainly have been reasonable for the OCCA to conclude the jury’s misunderstanding of the law did not flow from the trial court's penalty-phase instructions. The OCCA’s follow-up conclusion, that because the jury’s confusion did not flow from those instructions it did not exist, however, is inconsistent with the state court record. In completely discounting the jury's note from its coercion calculus, the OCCA did not just err, it reached an unreasonable determination in light of the record before it. 28 U.S.C. § 2254(d). 29 . See Woodson v. North Carolina, 428 U.S. 280, 305, 96 S.Ct. 2978, 49 L.Ed.2d 944 (1976) (<HOLDING>); Coleman v. Brown, 802 F.2d 1227, 1238-39
holding that execution of a defendant who commits a capital crime while under the age of eighteen is prohibited by the eighth amendment holding that the fdpas relaxed evidentiary standard does not impair the reliability or relevance of information at capital sentencing hearings but helps to accomplish the individualized sentencing required by the constitution holding the eighth amendment requires that sentencing procedures in capital cases be evaluated under a heightened standard of reliability holding that use of a victim impact statement during sentencing violated the eighth amendment holding that the right applies at capital sentencing in particular