In the 1905 case of Felts v. Murphy, Warden, the United States Supreme Court dealt with a habeas corpus petition from an inmate who was convicted and sentenced to death in Virginia for murder. The petitioner argued that his constitutional rights were violated because he was not provided with counsel during his trial, as required by the Sixth Amendment. However, at that time, this provision only applied to federal cases and not state trials like Felts'. Therefore, the Supreme Court ruled against him stating that there had been no violation of his constitutional rights since states were not obligated under federal law to provide legal representation in capital cases until it became mandatory after Gideon v. Wainwright (1963). Thusly affirming lower court's decision denying relief.

The dissenting opinion in the case of Felts v. Murphy, Warden argued that the majority's decision to uphold a lower court ruling denying habeas corpus relief was incorrect. The dissent believed that there were significant issues with how evidence was obtained and used during trial which violated Felts' constitutional rights. They contended that these violations should have been enough to grant him a new trial or at least reconsideration by an appellate court. Furthermore, they disagreed with the majority's interpretation of relevant legal precedents and felt their colleagues had not adequately considered all aspects of this complex case before reaching their conclusion.