In Simmons v. South Carolina, the defense was allowed to have a jury instructed about parole ineligibility when the prosecution argued future dangerousness.

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In Simmons v. South Carolina (1994), the U.S. Supreme Court held that when a prosecutor argues future dangerousness as a reason for imposing the death penalty, the defense is entitled to inform the jury about the defendant's parole ineligibility if sentenced to life imprisonment instead.

In Simmons V