During the next four years, 37 states enacted new death penalty laws intended to overcome the court's concerns about the arbitrary imposition of the death penalty. Several statutes that mandated bifurcated trials, with separate guilt-innocence and sentencing phases, and imposing standards to guide the discretion of juries and judges in imposing capital sentences, were upheld in a series of Supreme Court decisions in 1976, beginning with "Gregg v. Georgia". Other statutes enacted in response to "Furman," such as Louisiana's (which mandated imposition of the death penalty upon conviction of a certain crime), were invalidated for cases of that same year.