In Bollenbach v. United States (1945), the U.S. Supreme Court ruled in favor of Carl Bollenbach, who was convicted for his role in a bank robbery based on circumstantial evidence and an incorrect jury instruction from the trial judge regarding "aiding and abetting." The court held that when a case is submitted to the jury with instructions that are misleading or inadequate to guide its deliberations, it infringes upon the defendant's right to fair trial as guaranteed by Sixth Amendment of Constitution. Justice Frankfurter wrote for majority stating that courts must be vigilant not only against violations of specific constitutional guarantees but also against any undermining of essential ingredients needed for a fair trial. He emphasized on importance of correct guidance from judges during trials especially where complex legal concepts like 'aiding and abetting' are involved which could potentially confuse jurors if not properly explained.

In the dissenting opinion for Bollenbach v. United States, Justice Frankfurter argued that the majority's decision to overturn Bollenbach's conviction due to a judge’s error in jury instruction was incorrect. He contended that while it is important for judges to provide accurate instructions, errors should not automatically lead to reversals of convictions if they do not significantly impact the trial's outcome. According to him, this new standard would place an undue burden on courts and could potentially result in numerous retrials based on minor technicalities rather than substantive issues of justice or fairness. Furthermore, he believed that there was sufficient evidence presented at trial supporting Bollenbach’s guilt which outweighed any potential confusion caused by erroneous instructions given by the judge.