Whether Oklahoma's "moral culpability" jury instruction, which restricts consideration of mitigating evidence of a defendant's mental health and background to only those factors that reduce his moral culpability for the crime, violates the Eighth and Fourteenth Amendments under Lockett v. Ohio, 438 U.S. 586 (1978), and Eddings v. Oklahoma, 455 U.S. 104 (1982), by preventing the jury from considering and giving effect to all relevant mitigating evidence in capital sentencing.

Whether the Eighth Amendment requires a sentencer to consider mitigating evidence of a capital defendant's mental health and background when determining moral culpability