In Byford v. State, 994 P.2d 700 (Nev. 2000), the defendant was convicted of first degree murder and sentenced to death. In determining the sentence, the jury relied upon the aggravating circumstance that "the murder involved torture or the mutilation of the victim." Id. at 716. The court rejected the defendant's challenge to the applicability of that aggravator, finding that it encompassed mutilation of the victim after death and that mutilation included setting the victim's body on fire: "We agree with the State's assertion that the legislative intent in making mutilation an aggravating circumstance "was to discourage the desecration of a fellow human being's body." We therefore take this opportunity to expressly hold that mutilation, whether it occurs before or after a victim's death, is an aggravating circumstance under NRS 200.033(8). Postmortem mutilation occurred here when Byford set the body on fire. . . ." Id. at 717.