In the case of Roland J. Bailey v. United States (1995), the Supreme Court ruled on whether a defendant's right to counsel was violated during plea negotiations, and if so, what constitutes an appropriate remedy for such violation. The court held that when a defendant demonstrates that his attorney’s performance fell below an objective standard of reasonableness and prejudiced his defense, he is entitled to relief under Strickland v. Washington (1984). However, in this particular case where Bailey pleaded guilty due to ineffective assistance from his lawyer during plea bargaining process but later received a fair trial with effective representation before entering another guilty plea; it was determined that there had been no Sixth Amendment violation because any earlier deficiency did not affect the fairness or reliability of the proceedings leading up to final conviction.

The dissenting opinion in the case of Roland J. Bailey v. United States argued that the majority's decision to uphold Bailey's conviction under 18 U.S.C §924(c) was a misinterpretation of the statute, which criminalizes "using or carrying" a firearm during and in relation to any crime of violence or drug trafficking crime. The dissent contended that merely possessing a firearm at one’s residence does not equate to “using” it during and in relation to another offense, as required by law for conviction under this statute. They believed that there must be an active employment of the weapon directly tied with the predicate offense for such charges to stand validly. In their view, upholding Bailey’s conviction based on his mere possession expanded this federal gun law beyond its intended scope and could lead to potential misuse against individuals who are not actively using firearms while committing other crimes.