In the 1993 case Jimmie Burden, Jr. v. Walter Zant, Warden, the U.S Supreme Court addressed an appeal by a death row inmate in Georgia who claimed his constitutional rights were violated during sentencing because of racially biased jury selection. Jimmie Burden Jr., an African American man convicted for murder and robbery, argued that prosecutors had systematically excluded black jurors from his trial which resulted in him being sentenced to death by an all-white jury. The court ruled against Burden's claim stating he failed to prove racial discrimination in juror exclusion as required under Batson v Kentucky (1986). This ruling reaffirmed that defendants must provide clear evidence of purposeful racial discrimination in jury selection to successfully challenge their conviction or sentence on those grounds.

In the dissenting opinion for Jimmie Burden, Jr. v. Walter Zant, Warden (1993), it was argued that the majority's decision to deny habeas corpus relief to Mr. Burden was incorrect because it failed to consider important factors in his case. The dissent pointed out that there were serious issues with how evidence had been handled during Mr. Burden's trial and believed these errors could have significantly impacted its outcome, potentially leading to a wrongful conviction of murder and death sentence for him. Furthermore, they disagreed with the majority’s application of procedural default rules which prevented federal courts from reviewing state court decisions if a defendant did not comply with certain state procedural requirements at trial or on appeal - arguing this approach unfairly penalized defendants who may not have understood complex legal procedures or had ineffective counsel representing them.