In the case of Dugger, Secretary, Florida Department of Corrections, et al. v. Adams in 1988, the United States Supreme Court ruled on a matter concerning jury instructions and capital punishment sentencing. The petitioner was James Adams who had been convicted for first-degree murder and sentenced to death by a Florida court. His appeal argued that his constitutional rights were violated because jurors were not properly instructed about mitigating circumstances which could have potentially led to a lesser sentence than death penalty. The Supreme Court held that there was no violation as it found that the trial judge's instruction did not prevent consideration of any relevant mitigating factors or evidence presented by Adams' defense team during sentencing phase. It also noted that even if such an error occurred at state level courts regarding jury instructions on mitigation issues in capital cases, it would not necessarily require federal habeas corpus relief unless defendant can establish actual prejudice resulted from this error.

In the dissenting opinion for Dugger, Secretary, Florida Department of Corrections, et al. v. Adams (1988), Justice White argued that the majority's decision to grant habeas corpus relief was incorrect because it failed to consider whether any alleged error in jury instructions had a substantial and injurious effect on the verdict. He contended that even if there were errors in instructing jurors about mitigating circumstances during sentencing phase of Adams' trial, these did not necessarily have an impact on his death sentence as he was also convicted for first-degree murder and armed robbery which carried mandatory life sentences without parole eligibility for 25 years. Therefore, according to Justice White's view, granting relief based solely on potential instructional errors related only to capital sentencing seemed unwarranted given other severe penalties imposed by law upon conviction for such serious crimes.