In the case of Aikens v. California (1971), the United States Supreme Court addressed an appeal from a death row inmate, James Aikens, who argued that his constitutional rights were violated during his trial for murder in California. The main issue was whether or not it was unconstitutional to exclude potential jurors who expressed general objections to capital punishment but did not indicate that they would automatically vote against it in all cases. The court ruled 6-3 against Aikens, upholding the constitutionality of excluding such jurors and affirming his conviction and sentence. The majority opinion held that states have discretion to determine juror qualifications and can legitimately exclude those whose views on capital punishment could interfere with their duties as jurors. They noted this does not violate a defendant's right to an impartial jury under Sixth Amendment nor equal protection under Fourteenth Amendment. However, three justices dissented arguing these exclusions created juries biased in favor of conviction since those opposed or skeptical about death penalty are more likely than others to acquit defendants charged with capital crimes.

In the dissenting opinion for Aikens v. California, Justice William O. Douglas argued that the majority's decision to uphold a warrantless search of an automobile was in violation of the Fourth Amendment rights against unreasonable searches and seizures. He contended that there were no exigent circumstances justifying such a search without obtaining a warrant first, as required by law. Furthermore, he criticized the Court's reliance on "automobile exception" doctrine which allows police officers to conduct vehicle searches without warrants due to their mobile nature and lower expectation of privacy compared with homes or offices. In his view, this exception should not be used as an excuse for bypassing constitutional protections when it is feasible for law enforcement officials to secure a warrant before conducting their search.