In the 1971 case of Boyd v. Dutton, Warden, the U.S Supreme Court considered whether a state prisoner's federal habeas corpus petition was properly dismissed without an evidentiary hearing. The petitioner claimed that his guilty plea was coerced by threats from his attorney and induced by promises made to him about parole eligibility which were not fulfilled. He also alleged that he had been denied effective assistance of counsel due to these actions. However, both claims were rejected in lower courts without any hearings being held on them. The Supreme Court ruled in favor of Boyd stating that if factual issues are raised in a habeas corpus application, then it is necessary for an evidentiary hearing to be conducted unless the State has provided facts conclusively showing that the applicant is entitled to no relief or those facts have been previously developed at a state court hearing where they were resolved against the applicant.

In the dissenting opinion for Boyd v. Dutton, Warden, 1971 case, it was argued that the majority's decision to grant habeas corpus relief based on a violation of petitioner's Sixth Amendment right to counsel during a lineup identification process was incorrect. The dissent pointed out that there were no constitutional grounds for this ruling as the Supreme Court had previously held in United States v. Wade and Gilbert v. California that such violations are subject to harmless-error analysis rather than automatic reversal of conviction. Furthermore, they contended that even if there had been an error at trial regarding admission of evidence from the lineup identification process without counsel present, it would have been harmless beyond reasonable doubt given other overwhelming evidence against Boyd including his possession of stolen goods related to robbery charges and positive identifications by victims outside courtroom proceedings.