 Additionally Deck argued that his 8th Amendment rights had been violated because of the idea of reliable sentencing.This also ties into the idea of a biased jury.According to justices Souter and Stevens’ concurring opinion in the case of "Simmons v. South Carolina", the “Eight Amendment requires provision of accurate sentencing information as an indispensable prerequisite to a reasoned determination of whether a defendant shall live or die” (case from 1994).