In Roberts v. Louisiana, the U.S. Supreme Court ruled that a mandatory death sentence for first-degree murder was unconstitutional, violating the Eighth and Fourteenth Amendments' prohibition against cruel and unusual punishment. The case involved a Louisiana statute which required capital punishment for anyone convicted of first-degree murder, regardless of any mitigating circumstances or individual characteristics of the offender. The court held that this law failed to allow consideration of these factors in sentencing decisions, thereby making it overly broad and inflexible. This decision followed on from previous rulings where similar laws had been struck down in North Carolina (Woodson v. North Carolina) and Florida (Proffitt v.Florida). It further solidified the precedent set by Furman v.Georgia (1972), wherein arbitrary application of death penalty was deemed unconstitutional.

In the dissenting opinion for Roberts v. Louisiana, Justice White argued that the majority's decision to invalidate a mandatory death penalty statute was inconsistent with previous Supreme Court rulings and failed to consider the state's interest in deterring serious crimes. He contended that there was no constitutional basis for ruling out capital punishment altogether or requiring individualized sentencing in all cases involving capital offenses. Furthermore, he believed that it should be left up to legislatures rather than courts to decide on appropriate penalties for different types of murder. In his view, this would allow states more flexibility in responding to public concerns about crime and justice.