In Carruthers v. State, the Georgia Supreme Court addressed the very "precise line" that must be drawn between religious references that are permissible and those that must not be allowed in the sentencing phase of capital cases. Specifically, the court held that the prosecutor's use of direct quotations from the Bible "invoked a higher moral authority and diverted the jury from the discretion provided to them under state law." The court ultimately found that the allowance of these direct religious references, over the objection of defense counsel, constituted an impermissible violation of defendant's right to due process.
Henson, Marcus S.
"Carruthers v. State: Thou Shalt Not Make Direct Religious References in Closing Argument,"
Mercer Law Review: Vol. 52
, Article 8.
Available at: https://digitalcommons.law.mercer.edu/jour_mlr/vol52/iss2/8