In Angelet v. Fay, Warden (1964), the petitioner, a Puerto Rican citizen convicted of first-degree murder in New York and sentenced to death, appealed his conviction on the grounds that he was denied due process because Spanish-speaking jurors were systematically excluded from his trial jury. The Supreme Court held that there was no constitutional requirement for juries to be composed of persons familiar with the native language of defendants. It also found no evidence supporting Angelet's claim about systematic exclusion of Spanish-speaking individuals from jury service in Bronx County where he was tried. Therefore, it affirmed lower court decisions denying habeas corpus relief.

In the dissenting opinion for Angelet v. Fay, it was argued that the majority's decision to deny habeas corpus relief was incorrect. The dissenting justices believed that Angelet had not been given a fair trial due to several factors including language barriers and lack of counsel during critical stages of his trial. They also pointed out that he did not fully understand his rights or the charges against him because they were explained in English, which was not his first language. Furthermore, they disagreed with the majority's view on harmless error doctrine application in this case as they felt it undermined constitutional protections for defendants who may be innocent but are unable to effectively defend themselves due to systemic issues within the criminal justice system.