In Boulden v. Holman, Warden (1968), the U.S Supreme Court ruled in favor of petitioner Charles Edward Boulden, who was convicted for robbery by an Alabama state court and sentenced to death. The case centered around whether or not a confession obtained from Boulden while he was held without access to counsel could be used against him at trial. The Supreme Court found that his constitutional rights were violated under the Fifth and Fourteenth Amendments as he had not been adequately informed of his right to remain silent or have legal representation during police interrogation. Furthermore, it was determined that there wasn't enough evidence beyond this unlawfully obtained confession to justify the conviction. Therefore, the judgment of conviction by Alabama courts was reversed and remanded for further proceedings consistent with this opinion.

In the dissenting opinion for Boulden v. Holman, Justice Harlan argued that the majority's decision to grant habeas corpus relief was based on a misinterpretation of Alabama law and an overextension of federal authority into state matters. He contended that there was no clear evidence showing that Boulden did not understand his rights or had been coerced into waiving them during police questioning. Furthermore, he disagreed with the majority's view that any doubt about whether a defendant understood their rights should automatically result in exclusion of their statements from trial. Instead, he believed this issue should be left to local courts to decide based on individual circumstances rather than being dictated by blanket federal rules.