In the 1960 case of Atchley v. California, the U.S Supreme Court upheld a murder conviction against Mr. Atchley who was accused of killing his wife in Arizona and then driving her body to California where he attempted to dispose it by burning. The key issue at hand was jurisdiction; whether or not California had authority over a crime that occurred in another state but had effects within its borders. In a 5-4 decision, the court ruled that since part of the criminal act (disposing of evidence) took place in California, it could assert jurisdiction over this matter under its "affects" doctrine which allows for prosecution if an out-of-state action has significant impact within state lines. This ruling set precedent for future cases involving cross-border crimes.

In the dissenting opinion for Atchley v. California, it was argued that the petitioner's constitutional rights were violated due to an unfair trial. The dissenting justices believed that Mr. Atchley did not receive a fair and impartial trial as guaranteed by the Fourteenth Amendment because of prejudicial publicity surrounding his case prior to and during his trial. They contended that this adverse pre-trial publicity influenced public sentiment against him, thereby denying him a fair hearing in court. Furthermore, they asserted that he was denied effective assistance of counsel since his lawyer had only one day to prepare for such a serious capital offense case before going into preliminary hearings which is insufficient time under any standard of fairness or justice.