In Gregg v. Georgia (1976), the U.S. Supreme Court held statistical attempts to evaluate the worth of the death penalty as a deterrent to crime inconclusive. Since the 'Gregg' decision, Ehrlich's deterrence findings have been discredited and even reversed. Careful review of other studies has revealed a balance of brutalization over deterrence results. Close examination of homicide data from earlier studies has shown consistent evidence of a brutalizing effect. Recent studies using monthly homicide data have provided more reliable statistical evidence of brutalization. Phillips' study, contrary to its original claims, should properly be counted among those studies finding statistically significant support for the brutalization hypothesis. 29 notes, 97 references.