In the case of Michael Donald Dodd v. United States, 2004, the U.S Supreme Court upheld a death sentence despite claims that jurors were improperly influenced by a prosecution exhibit during sentencing deliberations. The defendant argued that his constitutional rights were violated when jurors viewed an exhibit displaying various forms of execution methods throughout history. He claimed this was prejudicial and inflamed their passions against him. However, the court ruled in favor of the government stating there was no clear evidence to suggest that viewing such material had any significant impact on jury's decision-making process or outcome of sentencing phase trial proceedings. Furthermore, it held that even if some prejudice did occur due to exposure to this information, it would not have been sufficient enough to affect overall fairness and integrity of judicial proceedings as required for reversal under Brecht standard (a test used by courts to determine whether a constitutional error is harmless). Therefore, Dodd’s conviction and sentence remained intact.

In the dissenting opinion for Michael Donald Dodd v. United States, Justice Stevens argued that the majority's interpretation of federal law was incorrect and overly broad. He contended that a death sentence should only be imposed if a jury unanimously finds beyond reasonable doubt at least one statutory aggravating factor making the crime eligible for capital punishment, as well as additional non-statutory factors justifying such severe penalty. In this case, he believed that while jurors unanimously agreed on eligibility due to kidnapping resulting in death (statutory), they did not reach unanimity on any specific non-statutory aggravating factors - some found different ones proven than others. Thus, according to Stevens' view of how federal law should work in capital cases, it would mean there wasn't proper unanimous agreement justifying imposition of death penalty here; hence he disagreed with affirming Dodd's sentence.