In Costarelli v. Massachusetts (1974), the U.S Supreme Court upheld a decision by the Massachusetts Supreme Judicial Court, which had denied an appeal from Peter J. Costarelli who was convicted of first-degree murder and sentenced to life imprisonment without parole. The case centered on whether or not there were constitutional errors in his trial that would warrant a new one. Specifically, Costarelli argued that he was denied due process because the jury saw him in handcuffs during his trial and because they heard about his prior criminal record; both of these factors could have prejudiced them against him unfairly. However, the Supreme Court found no merit in these arguments as it concluded that any potential prejudice did not rise to a level constituting denial of fair trial under Fourteenth Amendment's Due Process Clause.

In the dissenting opinion for Costarelli v. Massachusetts, Justice William O. Douglas argued that the majority's decision was a violation of due process rights under the Fourteenth Amendment. He contended that it is fundamentally unfair to deny an individual his livelihood based on accusations without providing him with an opportunity to confront and cross-examine his accusers or present evidence in defense of himself. In this case, a teacher had been dismissed from his job based on anonymous letters accusing him of misconduct but was not given any chance to challenge these allegations directly during proceedings before school authorities or courts. The justice emphasized that such procedures are contrary to basic principles of fairness and justice embedded in American legal tradition and constitutional law.