In the case of Charlotte Jenkins, Warden v. Percy Hutton, the Supreme Court was asked to review a decision made by the Sixth Circuit that granted habeas relief to Percy Hutton for his 1986 conviction in Ohio state court for murder and other crimes. The issue at hand was whether or not the jury instructions during Hutton's trial were constitutionally inadequate because they failed to specify which actions constituted an "aggravating circumstance" necessary for imposing a death sentence. The Sixth Circuit ruled in favor of Hutton, stating that these instructions violated his due process rights under the Fourteenth Amendment. However, upon review, the Supreme Court reversed this decision on June 19th, 2017. They argued that it is not established law that a jury must be instructed about how to identify an aggravating circumstance when considering capital punishment; therefore there could be no violation of due process rights as claimed by Hutton and upheld by the Sixth Circuit. This ruling reaffirmed both federalism principles (the power balance between states and federal government) and limitations on habeas corpus relief (a legal action against unlawful detention).

In the dissenting opinion for Charlotte Jenkins, Warden v. Percy Hutton, it was argued that the majority had misapplied federal law in denying Hutton's habeas corpus petition. The dissent pointed out that Ohio courts had failed to instruct jurors properly on how they should weigh evidence related to an aggravating circumstance against mitigating factors during sentencing. This error could have led them to impose a death sentence without fully considering all relevant circumstances of the case as required by law. Despite this procedural flaw, which may have resulted in a violation of Hutton’s constitutional rights, his appeal was rejected because he did not raise this issue at trial or on direct review and thus defaulted under state law according to the majority view. However, from a dissenter's perspective such strict application of procedural default rules undermines confidence in judicial proceedings and fails to ensure fair treatment for defendants facing severe penalties like capital punishment.