In Eddings v. Oklahoma, the U.S. Supreme Court ruled in 1982 that a sentencing court must consider all mitigating factors presented by the defense during the penalty phase of a capital murder trial. The case involved Monty Lee Eddings, who was convicted for first-degree murder at age 16 and sentenced to death without consideration of his troubled upbringing as potential mitigation evidence. The Oklahoma courts affirmed this sentence, stating that they could not consider such aspects in mitigation under state law. However, on appeal to the Supreme Court, it was held that this refusal violated Eddings' Eighth and Fourteenth Amendment rights because it prevented full consideration of relevant character and record before imposing death penalty. Therefore, while upholding his conviction for first-degree murder, they remanded for resentencing with instructions to include all mitigating circumstances.

In the dissenting opinion for Eddings v. Oklahoma, Justice Burger argued that the majority had overstepped its bounds by reevaluating evidence and making independent determinations about its significance. He contended that this was a role reserved for trial courts, not appellate courts like the Supreme Court. Furthermore, he disagreed with the majority's view on mitigating factors in capital punishment cases; while they believed such factors must always be considered regardless of their relevance to moral culpability, he felt only those directly related should be taken into account. In his view, allowing all mitigating circumstances could lead to arbitrary results where similar crimes receive vastly different penalties based on unrelated personal characteristics or experiences of defendants.