In Roberts v. Louisiana, 428 U.S. 325 (1976), the Supreme Court invalidated Louisiana's mandatory death sentence statute because under that statute "every jury in a first-degree murder case is instructed on the crimes of second-degree murder and manslaughter and permitted to consider those verdicts even if there is not a scintilla of evidence to support the lesser verdicts." The Court concluded that the sentencing scheme "not only lacks standards to guide the jury in selecting among first-degree murders, but it plainly invites the jurors to disregard their oaths and choose a verdict for a lesser offense whenever they feel the death penalty is inappropriate." Id. at 335. The Court condemned the "element of capriciousness" that arose from "making the jurors' power to avoid the death penalty dependent on their willingness to accept this invitation to disregard the trial judge's instructions." Id.