Which of the Following Has Not Been Identified as a Source

Which of the following has not been identified as a source of arbitrariness in the administration of the death penalty?

A) post-Furman statutes that justify arbitrariness
B) jurors' misunderstanding or underestimating their sentencing obligations
C) rule changes by the Supreme Court
D) problems in determining murderous intent
E) all of the above have been identified as sources of arbitrariness