In the 1961 case Gallegos v. Colorado, a minor was convicted of delinquency based on his confession to robbery and assault charges. The U.S Supreme Court overturned this conviction due to concerns about the treatment of minors during police interrogations. The minor in question, a fourteen-year-old boy named Richard Gallegos, had been held by Denver police for five days without access to legal counsel or contact with his parents before he confessed to the crimes. In their ruling, the court emphasized that juveniles are more susceptible than adults under coercive circumstances and therefore require additional protections during criminal proceedings. They concluded that holding a juvenile for an extended period without providing them access to adult advice violates their rights under the Due Process Clause of Fourteenth Amendment.

In the dissenting opinion for Gallegos v. Colorado, Justice Frankfurter argued that the majority had overstepped its bounds by reevaluating facts and witnesses' credibility, a task he believed should be left to state courts. He noted that there was no clear evidence of coercion or intimidation in obtaining the confession from Gallegos, who was 14 at the time of his arrest for murder. The justice also pointed out that while it is important to protect minors during police interrogation processes, this protection should not extend so far as to exclude any confessions made by juveniles without counsel present. Furthermore, he expressed concern about setting a precedent where federal courts could overturn state court decisions based on their own interpretation of facts rather than on constitutional grounds.