The U.S. Supreme Court case Maynard, Warden, et al. v. Cartwright in 1987 revolved around the issue of whether a jury instruction that limited consideration of mitigating circumstances to those listed in an Oklahoma statute violated the Eighth and Fourteenth Amendments' prohibition against cruel and unusual punishment. The petitioner was convicted for first-degree murder and sentenced to death by an Oklahoma court which instructed jurors they could only consider certain statutory factors as potential mitigation when deciding on his sentence. The defendant appealed this decision arguing it prevented him from presenting relevant mitigating evidence about his character or record not covered by these specific factors - thus violating his constitutional rights under Lockett v Ohio (1978). In a unanimous decision, the Supreme Court agreed with Cartwright's argument stating that limiting juror consideration of mitigating circumstances violates both amendments because it prevents defendants from introducing any aspect of their character or record as part of their defense.

In the dissenting opinion for Maynard, Warden, et al. v. Cartwright (1987), Justice White argued that the majority's decision to overturn Cartwright's death sentence was incorrect because it misinterpreted Oklahoma law and ignored precedent set by previous Supreme Court cases. He contended that Oklahoma law did not require a jury to find beyond a reasonable doubt that aggravating circumstances outweighed mitigating ones in order to impose a death sentence; rather, it only required them to determine if one or more aggravating factors existed at all. Furthermore, he believed the court had previously upheld similar sentencing schemes in other states as constitutional under Gregg v Georgia (1976). Therefore, he felt there was no reason why Oklahoma’s should be considered different or unconstitutional.