Midway through the penalty phase, Manson shaved his head and trimmed his beard to a fork; he told the press, "I am the Devil, and the Devil always has a bald head." In what the prosecution regarded as belated recognition on their part that imitation of Manson only proved his domination, the female defendants refrained from shaving their heads until the jurors retired to weigh the state's request for the death penalty.
On the day the verdicts recommending the death penalty were returned, news came that the badly decomposed body of Ronald Hughes had been found wedged between two boulders in Ventura County. It was rumored, although never proven, that Hughes was murdered by the Family, possibly because he had stood up to Manson and refused to allow Van Houten to take the stand and absolve Manson of the crimes. Though he might have perished in flooding, Family member Sandra Good stated that Hughes was "the first of the retaliation murders."