In the case of Crooker v. California, 1957, the U.S. Supreme Court ruled in favor of California by a vote of five to four. The defendant, William Marshall Crooker was convicted for burglary and sentenced to life imprisonment under California's habitual criminal statute after he refused legal counsel during his trial despite being offered it multiple times by the court. He appealed on grounds that his constitutional rights were violated because he wasn't provided with an attorney during police interrogation post-arrest which led him making incriminating statements used against him at trial. The majority opinion held that while defendants have a right to counsel during their trials as per Sixth Amendment, this does not extend to pre-trial interrogations or investigations conducted by law enforcement agencies before formal charges are filed; thus no violation occurred when Crooker was questioned without an attorney present. This decision reflected prevailing views about limits on right-to-counsel protections at that time but would later be significantly modified by subsequent landmark rulings like Miranda v Arizona (1966) which extended these protections further into custodial interrogations.

In the dissenting opinion for Crooker v. California, Justice Frankfurter argued that the majority's decision was inconsistent with previous rulings regarding a defendant's right to counsel during police interrogation. He believed that denying Crooker access to his attorney while he was being interrogated violated his constitutional rights under the Sixth Amendment and Fourteenth Amendment due process clause. According to him, it is essential for an accused person to have legal representation when dealing with law enforcement officials in order not only to protect their rights but also ensure fair proceedings. Furthermore, he expressed concern about potential abuses of power by authorities if they were allowed unrestricted access to defendants without any legal oversight or protection from attorneys present during questioning sessions.