Lowenfield v. Phelps, 484 U.S. 231 (1988), is a United States Supreme Court case.

This is simply because the single statutory "aggravating circumstance" found by the jury duplicates an element of the underlying offense of first-degree murder.

In 1984, Leslie Lowenfield, a Guyanese immigrant welder, was convicted of the 1982 killing of his girlfriend, a sheriff's deputy, and four members of her family, including a 4-year-old girl.

[1] The court, in an opinion by Chief Justice Rehnquist, held that the trial judge's polling of the jury and supplemental Allen instruction did not coerce the jury to return a verdict of guilty.

The aggravating circumstance in the case, intentionally killing more than one person was found by the jury in the guilt phase after returning three first-degree murder verdicts.