The U.S. Supreme Court case Roberts v. Louisiana in 1976 dealt with the constitutionality of mandatory death sentences for certain crimes, specifically first-degree murder convictions. The court ruled that such mandatory sentencing was unconstitutional under the Eighth and Fourteenth Amendments, which prohibit cruel and unusual punishment and guarantee due process respectively. In this particular case, a man named Robert Willie had been convicted of first-degree murder in Louisiana state court and automatically sentenced to death according to state law at the time. However, his sentence was overturned by the Supreme Court's decision because it did not allow for consideration of individual circumstances or mitigating factors related to each defendant's situation.

In the dissenting opinion for Roberts v. Louisiana, Justice White argued that the majority's decision to invalidate Louisiana's death penalty statute was inconsistent with previous court rulings and disregarded state sovereignty in determining appropriate criminal punishments. He contended that states should have discretion over their own legal systems, including setting penalties for crimes such as murder. Furthermore, he criticized the majority’s reliance on public opinion surveys to determine “cruel and unusual punishment,” arguing this approach was subjective and unreliable. Instead of focusing on societal consensus or personal beliefs about morality, Justice White believed courts should defer to legislative judgments unless they clearly violate constitutional principles. In his view, there wasn't sufficient evidence proving a national consensus against capital punishment at that time; thus it shouldn’t be deemed unconstitutional per se.