One remaining problem area is in the communications between the trial court and the deadlocked jury. The Supreme Court continues to be dangerously unclear as to the constitutional parameters within which such communications must operate. These communications most often take the form of supplemental charges to the jury and inquiries into the numerical breakdown of a divided sentencing jury. These practices raise concern in capital cases because of the potential risk of jury coercion that they create. The history and development of the Supreme Court's treatment of the death penalty, the development of procedural parameters necessary to avoid the infliction of cruel and unusual punishment, and the emphasis on individualization in capital sentencing are discussed. Also examined is the role of the jury in capital cases including the effects of both supplemental jury charges and inquiries into the numerical division of a jury. 202 footnotes.