In the case of Chessman v. Teets, Warden in 1955, Caryl Chessman was convicted for robbery, kidnapping and rape under California's "Little Lindbergh Law". The law allowed a death sentence if harm or injury occurred during a kidnap event even if it wasn't lethal. Chessman represented himself at trial without counsel and was sentenced to death. He appealed his conviction on grounds that he had been denied due process because he did not have legal representation during his trial and that the interpretation of the Little Lindbergh Law was unconstitutional as applied to him. The U.S Supreme Court upheld his conviction stating that there were no constitutional issues involved in this case since Chessman had chosen to represent himself despite being offered legal aid by the court several times. Furthermore, they found nothing wrong with how California interpreted its own laws regarding punishment for kidnapping offenses.

In the dissenting opinion for Chessman v. Teets, Justice Hugo Black argued that Caryl Chessman's constitutional rights were violated during his trial and conviction in California state court. He believed that Chessman was denied due process because he did not have adequate legal representation at crucial stages of his trial and appeal process, including when he was sentenced to death. Furthermore, Justice Black contended that the majority's decision failed to uphold the principles of fairness and justice inherent in American law by allowing a potentially flawed verdict to stand without thorough review or consideration of all relevant factors. This case raised serious questions about procedural safeguards necessary for fair trials under U.S constitution which according to him were overlooked by majority justices.