In Bullock v. South Carolina (1960), the U.S Supreme Court ruled in favor of the petitioner, Nathaniel Bullock, who was convicted for burglary and sentenced to death by a South Carolina court. The case centered on whether or not Bullock's constitutional rights were violated due to his inability to afford counsel during his trial. The Supreme Court held that under the Fourteenth Amendment’s Due Process Clause, states are required to provide legal representation for defendants unable to afford their own lawyers in capital cases where life is at stake. This ruling overturned Bullock's conviction and sentence as it found that he had been denied fair trial because he did not have access to adequate legal representation during his initial trial proceedings.

In the dissenting opinion for Bullock v. South Carolina, Justice Frankfurter argued that the Court should not have taken jurisdiction over this case because it was a matter of state law rather than federal constitutional law. He believed that the majority had improperly interpreted and applied the Fourteenth Amendment's Due Process Clause to overturn a conviction based on an alleged violation of procedural rules in a state court trial. According to Justice Frankfurter, such issues were better left to be resolved by state courts and legislatures who are more familiar with their own procedures and standards. Furthermore, he warned against expanding federal judicial power too broadly at the expense of states' rights and autonomy within our federal system.