In the case of Collins v. Johnston, Warden of the California State Prison in 1914, the U.S Supreme Court was tasked with determining whether a prisoner's constitutional rights were violated when he was denied access to legal counsel during his trial. The petitioner, Collins, had been convicted for murder and sentenced to death by a California court without being provided an attorney. He appealed this decision on grounds that it contravened his Sixth Amendment right to have assistance of counsel for his defense. The Supreme Court ruled against Collins' appeal stating that while federal courts are required under the Constitution’s Sixth Amendment to provide defendants with legal representation if they cannot afford one themselves; state courts did not have such obligation at that time as per Fourteenth Amendment due process clause interpretation then. This ruling reflected prevailing jurisprudence which held that certain Bill of Rights protections did not apply fully or directly to states until later landmark decisions like Gideon v Wainwright (1963) extended these requirements.

In the dissenting opinion for Collins v. Johnston, it was argued that the petitioner's constitutional rights were violated due to a lack of fair trial. The dissenting justices believed that there was an abuse of discretion by the lower court when they refused to grant a continuance in order for Collins' counsel to adequately prepare his defense. They contended that this refusal denied him his right to effective assistance of counsel and thus, deprived him of due process under law as guaranteed by the Fourteenth Amendment. Furthermore, they disagreed with how evidence from another crime committed by Collins was admitted into trial without proper context or explanation which could have prejudiced the jury against him unfairly. Therefore, these justices felt strongly that these errors warranted reversal and remand for a new trial where all procedural safeguards would be observed.