In the case of Yates v. Aiken, Warden, et al., 1987, the U.S. Supreme Court ruled in favor of petitioner Johnny Yates who was convicted for murder and sentenced to death by a South Carolina court. The issue at hand was whether or not the jury had been properly instructed on how to consider mitigating evidence when deciding upon a sentence. In this case, it was found that jurors were incorrectly led to believe they could only consider certain statutory factors as mitigating circumstances rather than considering all relevant aspects presented during trial proceedings which might warrant leniency. This misinterpretation violated Yates' Eighth Amendment rights against cruel and unusual punishment as well as his Fourteenth Amendment due process rights because it limited his ability to fully present a defense regarding sentencing considerations. Therefore, the Supreme Court reversed and remanded the decision back down for further proceedings consistent with its opinion.

In the dissenting opinion for Yates v. Aiken, Justice White argued that the majority's decision to reverse and remand was incorrect because it failed to properly apply the harmless-error doctrine. He contended that even if there had been an error in instructing the jury about intent, this would not have affected their verdict given other overwhelming evidence of guilt presented during trial. The dissent further noted that a reasonable juror could only conclude from such evidence that Yates intended to commit murder when he fired his gun at close range into a crowd of people. Therefore, any potential instructional error regarding intent should be considered harmless beyond a reasonable doubt under Chapman v California (1967). By failing to consider this point adequately, Justice White believed the majority unnecessarily prolonged litigation and potentially undermined public confidence in judicial proceedings by suggesting juries cannot reliably determine criminal intent based on clear factual evidence.