Legal mechanisms of penalty enhancement vary between jurisdictions. In the laws of Italy, Germany, Norway, and many parts of the United States, there are two or more "degrees" of murder, with wording such as: "...inflicting torture upon the victim prior to the victim's death"[4] typically used to rule that the highest degree should apply. In other jurisdictions, it may be that even if there was just one crime of murder, the sentencing practices and guidelines are such that the aggravating circumstance of any torture will nevertheless allow for a harsher than normal penalty.[5][6]