In the 1997 case of Angel Francisco Breard v. Fred W. Greene, Warden, the U.S Supreme Court denied a stay of execution and dismissed a writ of habeas corpus for Angel Francisco Breard, who was convicted in Virginia state court for attempted rape and murder. The Paraguayan national claimed that his rights under Article 36(1)(b) of the Vienna Convention on Consular Relations were violated because he was not informed upon arrest that he could request assistance from the Paraguayan consulate. However, this claim had been procedurally defaulted since it wasn't raised at trial or on direct review as required by state law. Furthermore, even if there had been no procedural default issue, relief would still be unavailable because an individual cannot enforce treaty-based rights absent implementing legislation from Congress or clear intent to self-execute within the treaty itself - neither present here with respect to Article 36(1)(b). Lastly, while international comity concerns are significant given potential implications for American citizens abroad facing criminal charges without consular access if other countries reciprocate our disregard for such provisions; these considerations do not override domestic legal principles requiring procedural default compliance.

In the dissenting opinion for Angel Francisco Breard v. Fred W. Greene, Justice Stephen Breyer argued that the court should have granted a stay of execution to allow further exploration of Breard's claim under the Vienna Convention on Consular Relations (VCCR). The VCCR requires authorities to inform foreign nationals arrested in another country about their right to contact their consulate. In this case, Breard was not informed and thus could not seek assistance from his home country, Paraguay. Justice Breyer believed that this violation might have affected his trial and sentencing due to lack of adequate legal representation or other support from Paraguayan officials. He also emphasized international comity concerns as well as potential harm to American citizens abroad if U.S fails to uphold its treaty obligations.