Bible use upheld in the penalty phase that resulted in a death verdict including a "court bailiff [who] provided a Bible to a deliberating juror, who then read aloud to his fellow deliberating jurors a passage concerning the Biblical mandate of 'an eye for an eye'" in Robins v. Polk, No. 05-1 (4th Cir. 2/14/2006). The Court split 2-1. The lower courts are fairly split on the issue, this is a matter in which cert is likely to be granted sooner, rather than later.