In the case of Estes v. Texas, 1964, Billie Sol Estes was convicted for swindling in a Texas state court. His trial had been broadcasted on television and radio which he argued violated his Fourteenth Amendment rights to due process as it influenced public opinion and potentially biased the jury against him. The U.S Supreme Court agreed with Estes' argument in an 8-1 decision stating that televising trials could indeed compromise a defendant's right to fair trial by influencing public sentiment and creating prejudice among jurors who might be exposed to such broadcasts before or during their service. Therefore, they ruled that broadcasting criminal trials should not be allowed if it infringes upon the defendant's constitutional rights.

In the dissenting opinion for Estes v. Texas, Justice Harlan argued that the presence of television cameras in a courtroom does not necessarily infringe upon a defendant's right to a fair trial. He contended that it is possible for media coverage and constitutional rights to coexist without conflict. According to him, there was no concrete evidence presented in this case proving that televised proceedings had prejudiced the jury against Estes or disrupted court decorum. Furthermore, he pointed out that many other publicized trials have occurred without any apparent harm done to justice being served. Therefore, he disagreed with the majority's decision which implied an absolute constitutional rule forbidding televised trials under all circumstances.