In the case of Bartone v. United States in 1963, the Supreme Court examined whether a federal court had jurisdiction over an appeal from a decision by the Secretary of Health, Education and Welfare to terminate disability benefits under Social Security Act. The appellant argued that he was entitled to judicial review because his constitutional rights were violated when his benefits were terminated without proper notice or hearing. However, the Supreme Court ruled against him stating that there is no right to judicial review unless it has been expressly granted by Congress. In this case, Congress did not provide for such review in decisions related to termination of disability benefits under Social Security Act.

In the dissenting opinion for Bartone v. United States, Justice Douglas argued that the petitioner should have been granted a new trial due to an error in jury instructions. He believed that the judge's instruction to jurors regarding reasonable doubt was misleading and could have confused them about their role in determining guilt or innocence. The justice emphasized that it is crucial for jurors to understand they must be convinced of guilt beyond a reasonable doubt before convicting someone, as this standard protects individuals from wrongful convictions. In his view, any deviation from this principle undermines fairness and justice within the legal system.