Means v. Dowd was a Supreme Court case that was decided in 1956. The case involved a challenge to the constitutionality of Indiana's death penalty statute. The petitioner, William Means, was convicted of murder and sentenced to death. He argued that the statute was unconstitutional because it did not provide for a jury trial or a hearing before a judge. The Supreme Court held that the statute was unconstitutional because it did not provide for a jury trial or a hearing before a judge. The Court reasoned that the right to a jury trial was a fundamental right that could not be denied without due process of law. The Court also held that the statute was unconstitutional because it did not provide for a hearing before a judge. The Court reasoned that a hearing before a judge was necessary to ensure that the death penalty was imposed in a fair and impartial manner. The Court's decision in Means v. Dowd was significant because it established that the right to a jury trial and a hearing before a judge were fundamental rights that could not be denied without due process of law. The decision also established that the death penalty could not be imposed without a hearing before a judge. The decision was a major victory for those who opposed the death penalty and it helped to ensure that the death penalty was imposed in a fair and impartial manner.

In the Supreme Court case of Means v. Dowd, Justice Douglas delivered a dissenting opinion in which he argued that the majority's decision was wrongfully decided and violated due process rights under the Fourteenth Amendment. He believed that petitioner's conviction should be overturned because his right to an impartial jury had been denied when jurors were dismissed for expressing doubts about their ability to reach a verdict without further deliberation. Furthermore, Justice Douglas noted that this dismissal occurred after only two hours of deliberations and before any real progress could have been made towards reaching a verdict; thus, it was premature and deprived Means of his constitutional right to trial by jury. Additionally, he contended that there had not been sufficient evidence presented at trial for means' guilt beyond reasonable doubt as required by law; therefore, justice Douglas concluded with his belief that petitioner’s conviction should be reversed on both grounds - lack of impartiality during jury selection and insufficient evidence presented at trial - as they constituted violations of due process rights guaranteed under the Fourteenth Amendment.