The U.S. Supreme Court case Abu-Ali Abdur'Rahman v. Ricky Bell, Warden in 2002 revolved around the issue of ineffective assistance of counsel during a capital sentencing proceeding. The petitioner, Abu-Ali Abdur'Rahman (formerly known as James Jones), was convicted for first-degree murder and sentenced to death in Tennessee state court. He claimed that his attorneys failed to adequately investigate and present mitigating evidence at his sentencing hearing which could have potentially resulted in a lesser sentence. Abdur’Rahman argued that this failure violated his Sixth Amendment right to effective assistance of counsel, but both the District Court and the Sixth Circuit denied relief on these claims stating they were procedurally defaulted because he had not raised them in state court. However, upon reaching the Supreme Court level it was ruled that federal courts can hear such claims if there is cause for defaulting on them at lower levels - meaning if there's reason why they weren't presented earlier - along with actual prejudice resulting from alleged violation of rights; or alternatively if failure to consider these would result in fundamental miscarriage of justice.

In the dissenting opinion for Abu-Ali Abdur'Rahman v. Ricky Bell, Warden (2002), it was argued that the majority's decision to deny habeas corpus relief was incorrect due to procedural errors in the original trial. The dissenting justices believed that there were significant issues with how evidence had been presented and handled during Abdur'Rahman's trial, which they felt undermined its fairness and reliability. They pointed out instances where potentially exculpatory evidence had not been disclosed by prosecutors or properly considered by the court, as well as concerns about ineffective assistance of counsel. Furthermore, they disagreed with the majority's interpretation of federal law regarding when a state prisoner can raise claims in a federal habeas petition after having previously raised them in state court proceedings. In their view, this case represented an instance where such repetition should have been allowed due to compelling circumstances.