In the 1985 case Lanier v. South Carolina, the U.S. Supreme Court addressed an appeal from a death row inmate named James Terry Lanier who was convicted of murder in South Carolina state court. The primary issue at hand was whether or not the trial judge had erred by refusing to instruct the jury that they could consider mitigating circumstances when deciding on a sentence for Lanier, even if all jurors did not agree on those circumstances. The Supreme Court ruled in favor of South Carolina, upholding Lanier's conviction and sentence. The decision reaffirmed that under existing law (Lockett v Ohio), while juries must be allowed to consider any relevant mitigating factors presented by defendants facing capital punishment, there is no constitutional requirement for judges to inform juries about their ability to do so without unanimous agreement among jurors regarding each individual factor.

In the dissenting opinion for Lanier v. South Carolina, it was argued that the majority's decision to uphold a state law requiring non-resident landowners to pay higher property taxes than resident landowners violated principles of equal protection under the Fourteenth Amendment. The dissenters believed that this differential treatment based on residency status did not serve any legitimate state interest and thus constituted an arbitrary discrimination against non-residents. They also pointed out that such discriminatory taxation could discourage interstate commerce and investment, which would be contrary to national interests. Furthermore, they disagreed with the majority's view that states have broad discretion in tax matters; while acknowledging this principle generally holds true, they contended it should not be used as a justification for violating constitutional rights.