In the Godfrey v. Georgia case of 1979, the U.S Supreme Court ruled that a death sentence imposed on William Theodore Godfrey was unconstitutional due to its vagueness under the Eighth and Fourteenth Amendments. The court held that Georgia's capital sentencing scheme failed to provide a meaningful basis for distinguishing between cases in which death penalty is imposed and those where it isn't. The crime committed by Godfrey involved killing his wife and mother-in-law but did not involve torture or any physical abuse beyond the act of killing itself, thus failing to meet Georgia’s statutory aggravating circumstances required for imposing a death penalty. Therefore, this ruling emphasized that states must clearly define what constitutes an aggravated offense deserving of capital punishment so as not to arbitrarily impose such severe sentences.

In the dissenting opinion for Godfrey v. Georgia, Justice White argued that the majority's decision to overturn Godfrey's death sentence was unjustified and inconsistent with previous rulings of the Court. He contended that there was no constitutional requirement for a state to precisely define what constitutes "outrageously or wantonly vile, horrible or inhuman" crimes deserving of capital punishment. Instead, he believed it should be left up to juries and appellate courts to interpret this language on a case-by-case basis. Furthermore, he disagreed with the majority's assertion that Godfrey’s crime did not meet these criteria as defined by Georgia law because it involved an instantaneous killing without torture or serious physical abuse beyond the act itself; instead arguing that any murder is inherently vile and inhuman enough to potentially warrant such punishment.