1. Magidson were guilty of murder; they just could not agree on whether the defendants should be found guilty of first-or seconddegree murder. Wronge, supra note 165 (noting that in Merel's case, two jurors voted in favor of firstdegree murder while ten jurors voted against, and in Magidson's case, seven jurors voted in favor of first-degree murder while five voted against). On retrial, the jury found both defendants guilty of second-degree murder;Cal. Ct. App,2009
2. Correction