found that capital punishment was unconstitutionally cruel and unusual, while three found that the statutes at issue were implemented in a random and capricious fashion, discriminating against blacks and the poor. Furman v. Georgia did not hold—even though it is sometimes claimed that it did—that capital punishment is per se unconstitutional. States with capital punishment rewrote their laws to address the Supreme Court's decision, and the Court then revisited the issue in a murder case: Gregg v. Georgia, . In Gregg, the Court ruled that Georgia's revised death penalty laws passed Eighth Amendment scrutiny: the statutes provided a bifurcated trial in which guilt and sentence were determined separately; and, the statutes provided for "specific jury findings" followed by state supreme court review comparing each death sentence "with the sentences imposed on similarly situated defendants to ensure that the sentence of death in a particular case is not disproportionate." Because of the Gregg decision, executions resumed in 1977. Some states have passed laws imposing mandatory death penalties in certain cases. The Supreme Court found these laws unconstitutional under the Eighth Amendment, in the murder case of Woodson v. North Carolina, , because these laws remove discretion from the trial judge to make an individualized determination in each case. Other statutes specifying factors for courts to use in making their decisions have been upheld. Some have not: in Godfrey v. Georgia, , the Supreme Court overturned a sentence based upon a finding that a murder was "outrageously or wantonly vile, horrible, and inhuman", as it deemed that any murder may be reasonably characterized in this manner. Similarly, in Maynard v. Cartwright, , the Court found that an "especially heinous, atrocious or cruel" standard in a homicide case was too vague. However, the meaning of this language depends on how lower courts interpret it. In Walton v. Arizona, , the Court found that the phrase "especially heinous, cruel, or depraved" was not vague in a murder case, because the state supreme court had expounded on its meaning. The Court has generally held that death penalty cases require extra procedural protections. As the Court said in Herrera v. Collins, , which involved the murder of a police officer, "the Eighth Amendment requires increased reliability of the process..." Punishments specifically allowed In Wilkerson v. Utah, the Court stated that death by firing squad is not cruel and unusual punishment under the Eighth Amendment. In Rummel