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the imposition of the death penalty on juvenile offenders under 18, and we now hold this is required by the Eighth Amendment.’).” Lewis v. State, 279 Ga. 756, 620 S.E.2d 778 (September 19, 2005). “Execution by lethal injection is not unconstitutional. Riley [ v. State, 278 Ga. 677, 689 (15), 604 S.E.2d 488 (2004)]; Dawson v. State, 274 Ga. 327, 334-335, 554 S.E.2d 137 (2001).” Accord, Williams v. State , 281 Ga. 87, 635 S.E.2d 146 (September 18, 2006). 13. DEATH PENALTY, EVIDENCE GENERALLY Spears v. State, 296 Ga. 598, 769 S.E.2d 337 (February 16, 2015). Capital murder and related convictions affirmed; death penalty upheld though evidence didn’t support one of two grounds for jury’s verdict. “[T]he trial court, in response to Spears's motion for a new trial, vacated the jury's finding regarding the statutory aggravating circumstance related to kidnapping with bodily injury because the evidence was insufficient to support a conviction for kidnapping with bodily injury under the definition of that crime that applied at the time of the murder. [Cit.] However, as Spears acknowledges, this Court has held that an insufficiency of the evidence to support one or more statutory aggravating circumstances found by the jury does not require reversal where a death sentence remains supported by at least one valid statutory aggravating circumstance. See Edenfield v. State, 293 Ga. 370, 392(13) (744 S.E.2d 738) (2013) (citing Zant v. Stephens, 462 U.S. 862 (103 S.Ct. 2733, 77 L.Ed.2d 235) (1983)).” Brockman v. State, 292 Ga. 707, 739 S.E.2d 332 (March 4, 2013). Felony murder and related convictions, and death penalty, affirmed; contrary to defendant’s argument, life sentence wasn’t required by State Constitution where defendant convicted of felony murder but not of malice murder. Argument based on “ Enmund v. Florida, 458 U.S. 782 (102 S.Ct. 3368, 73 L.Ed.2d 1140) (1982). The United States Supreme Court in Enmund held that a sentence of death violated the Eighth Amendment where the defendant was ‘the minor actor in an armed robbery, not on the scene, who neither intended to kill nor was found to have had any culpable mental state.’ Tison v. Arizona, 481 U.S. 137, 149(II) (107 S.Ct. 1676, 95 L.Ed.2d 127) (1987) (explaining Enmund ).” But Enmund has never been thought to prohibit a death sentence for felony murder “where the defendant ‘was an active participant in the events that led to the victim's death.’ Allen v. State, 253 Ga. 390, 395(7), 395 n. 3 (321 S.E.2d 710) (1984),” and “Brockman offers no persuasive reason why this Court should now hold that such a sentence violates the Georgia Constitution.” Bryant v. State, 288 Ga. 876, 708 S.E.2d 362 (March 18, 2011). Capital murder conviction affirmed, but sentence reversed based on improper victim impact testimony. Trial court properly excluded “evidence that Bryant was never offered a plea agreement. ‘Evidence concerning the machinations of the criminal justice system outside the defendant's control, such as whether the defendant was offered a plea bargain of life, is [ ] inadmissible [in the sentencing phase].’ Barnes [ v. State, 269 Ga. 345, 359-360(27) (496 S.E.2d 674) (1998)]. See Terrell v. State, 271 Ga. 783, 787(10) (523 S.E.2d 294) (1999) (holding that a defendant's conditional offer to plead guilty is not admissible in the sentencing phase).” Stinski v. State, 286 Ga. 839, 691 S.E.2d 854 (March 1, 2010). At defendant’s capital murder trial, 1. “[t]he trial court did not err by refusing to allow Stinski to present evidence and arguments about the likely date of his parole eligibility if he were sentenced to life with the possibility of parole for the murders. Lance v. State, 275 Ga. 11, 25(34) (560 S.E.2d 663) (2002). Such evidence and argument was generally not permitted by this Court prior to the addition of life without parole as a sentencing option. See Burgess v. State, 264 Ga. 777, 788-789(33) (450 S.E.2d 680) (1994) (distinguishing Simmons v. South Carolina, 512 U.S. 154 (114 S.Ct. 2187, 129 L.Ed.2d 133) (1994) (holding that, where the prosecution argues future dangerousness, a defendant who will never be eligible for parole if sentenced to imprisonment for life rather than to death is entitled to demand that the jury be informed of that fact)). See also Ga. L.1993, p. 1654 et seq. (providing for life without parole as an available sentencing option for certain crimes committed after the effective date of the act). The addition of life without parole as an available sentencing option makes such evidence and argument even less important, because a jury concerned about the defendant's future dangerousness if he or she were ever paroled need not resort to a death sentence but, instead, may foreclose the possibility of parole by imposing a sentence of life without parole. See OCGA § 17-10-31(b)(1) (authorizing, effective April 29, 2009, arguments and jury charges on life without parole that are identical to those that were originally authorized under OCGA § 17-10- 31.1(d)(1) when life without parole first became an available sentencing option).” 2. “Stinski was not entitled in the sentencing phase to make an unsworn statement or to testify subject only to limited cross-examination. Jenkins v. State, 269 Ga. 282, 294(22) (498 S.E.2d 502) (1998). Compare OCGA § 17-10-2(a)(2) (providing an opportunity for a death penalty defendant to make arguments to the jury “regarding the punishment to be imposed” through counsel, if represented by counsel, or pro se, if not).” 3. “The trial court did not err by excluding as irrelevant Stinski's evidence suggesting that the victim had killed her husband during a domestic abuse incident. See Barnes v. State, 269 Ga. 345, 357-